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Yorkshire Campaign for Nuclear Disarmament
Comments on the Draft Programmatic Environmental Impact Statement for the Ballistic Missile Defence System

 

Introduction

The Yorkshire Campaign for Nuclear Disarmament is a regional wing of British CND and it specialises in Missile Defence issues. It is one the leading UK Non-Governmental Organisations campaigning on Missile Defence, with particular emphasis placed on the two Missile Defence bases in Yorkshire – Fylingdales and Menwith Hill (the latter is yet to be officially confirmed as a Missile Defence facility).

Given our considerable interest in Missile Defence and its implications for global and UK security and stability, Yorkshire CND welcomes the opportunity to present our comments on the Draft Programmatic Environmental Impact Statement.

We are disappointed however that the PEIS will only be undertaken for component bases in the United States and not for overseas bases integral to the system, such as Fylingdales. From our experience of talking to the residents close to the Fylingdales base, we are aware of a constant concern about its role in the "Son of Star Wars" program and a desire for more information and accountability from the developers of the system. The local population in the vicinity of this base has both environmental and security concerns regarding the base’s role in Missile Defence that ought to be addressed in such a study. The same also applies for Menwith Hill – considered highly likely to play a key role as the Ground Based Relay Station for the Space Based Infra Red System - and these concerns will grow if the United States is granted permission to use the base for Missile Defence by the UK Government.

Furthermore, there exists a large, informed section of society, not necessarily within the vicinity of these particular bases, that is also legitimately concerned as to the potential impact on UK and global security as a result of the Missile Defence system. Despite the UK’s involvement in the system this group too will not be represented by this study.

Yorkshire CND, along with many concerned UK groups, did present submissions to the UK Parliament Defence Committee in late January 2003 as part of their investigation in to the potential use of Fylingdales for US Missile Defence, especially as the Ministry of Defence has repeatedly stated that it does not consider that the UK was under threat from a missile attack. However, since the public consultation period declared by the Secretary of State for Defence at the time (one month over the Christmas holidays and parliamentary recess) was completely inadequate, it gave no real opportunity for local residents or the general population of the UK to voice their concerns on this important issue. We hope therefore that the PEIS will give due attention to the views and concerns of residents affected by Missile defence beyond the shores of the US mainland.

Despite the fact that the PEIS has currently declared that it will only consider component bases of Missile Defence based in the US, we will refer to the Yorkshire bases both in the hope that the PEIS will recognise the importance of expanding its remit to cover Missile Defence bases beyond the USA mainland, and partly because the concerns that surround these bases can be equally applied to their US-based equivalents.

UK position

The UK Government has already granted permission for the USA to upgrade the Early Warning Radar at Fylingdales so that it may play a role in the Missile Defence system. Concerned observers of Missile Defence developments expect a similar request for use of Menwith Hill to come from the US in the future. The base has purpose-built downlink and relay elements for the Space-Based Infra-Red System (SBIRS), which will be integral to the US Missile defence system if and when the SBIRS satellite network is complete. It is also possible that the UK may host an X-Band Radar and/or Missile Defence interceptor missiles in the future.

Fylingdales

Fylingdales, and radars like it, present environmental concerns to the local population as a result of the possible harmful biological effects of the non-ionising radio frequency emissions from the radar. Whilst the radar beam itself projects 3° above the horizon, the beam releases leakage in the form of sidelobes. These sidelobes of pulsed low frequency radiation are the source of considerable anxiety to local residents. Such concerns are exacerbated by the obvious effects of the radar in the local area (such as car alarms being set off regularly for no apparent reason, car automatic locking systems being triggered and interference with radio and tape players in cars passing the base) and the knowledge that the similar Cape Cod radar base in the United States has seemingly significant cancer clusters in its vicinity (that has resulted a USAF supported study of the radar effects on health). In 2003 the then base commander of RAF Fylingdales confirmed to Yorkshire CND that the radar has "issues with leakage."

The paper "Is it Safe?" by Professor Dave Webb - Convenor of Yorkshire Campaign for Nuclear Disarmament – explains in more detail the environmental concerns over the radar radiation and it is attached as Appendix 1 to this paper.

Furthermore we would point out that the Fylingdales radar base is in the North York Moors National Park – a loved and protected area of the UK. It is already seen by many as an unsightly abomination cutting across the horizon of otherwise ancient and unspoilt moorland. An increased role for the base in a new, highly controversial global military network presents the potential for increased activity, expansion and increased policing, all of which will lead to environmental degradation of the moorland on which the base is situated and the surrounding countryside.

Menwith Hill

Menwith Hill overlooks but is excluded from the Nidderdale Area of Outstanding Natural Beauty. As with Fylingdales, it interferes with a region that has been specifically pinpointed as an area of special importance that deserves protection. The land the base is on would no doubt have been included in the area if it had not been already spoilt by the considerable military presence. Menwith Hill is again visible for miles around and is an inexcusable blot on an otherwise precious landscape. The base’s continual expansion and glaring nightlights only further interfere with this area.

Despite the base’s contention that it is an RAF base, the base is in all reality run by the US military and it is famously unaccountable to the UK people. Thus, its environmental impacts are less controllable and have become considerable. As an example, although the base does present planning applications to the local council, that council has no power to disapprove them and the base can build whatever it desires, where it desires, with the local community only being able to express its concern and hope that the base commanders will take some notice. This situation has led to fervent expansion with little or no consideration for the impact on the local community or environment.

The discovery of a colony of rare feral orchids in natural wetland on the north-west of the Base by Anne Lee of the WoMenwith Hill Women’s Peace Camp(aign), led to an investigation by one of the country’s top orchid experts. This research did lead to the re-routing of a proposed high security fence and an agreement to conserve the orchids’ site as a reserve. Such protection would not have been achieved if it were not for the discovery of a concerned citizen, since the base itself makes little effort to consider the environmental impact of its proposed developments.

Space

Missile Defence plans extend to the possible deployment of space-based weaponry and space-based weapons systems. It is crucial that the PEIS consider seriously the likely impact of space weapons deployment. The use of space weapons, for whatever reason, to attack or destroy objects outside of the atmosphere would produce space debris, changing the near Earth environment and would become a serious hazard to future space missions, even possibly preventing them from leaving Earth. At the speeds required to escape the Earth’s gravitational pull, the impact of just a tiny object on a space rocket could be disastrous. Space-based conflict of any sort could add to this problem enormously and it is an issue that deserves serious attention.

Further to this, plans for weapons such as the space-based laser may eventually incorporate the use of nuclear power. The deployment of nuclear powered satellites could be environmentally disastrous with considerable risk of high-level pollution at the point of initial launch, when in orbit (from attack or accident) and (if and when the orbit decays) during re-entry into the Earth’s atmosphere.

The deployment of space-based weapons will also present the problem of increased global instability and a degradation of arms control efforts. Such deployments are likely to provoke other states to respond in kind with their own developments and deployments. With no sufficient legal system controlling the non-WMD weaponisation of Outer Space, weapons deployment and the threat of opponents interfering with vulnerable systems, could provoke a highly destabilising and dangerous space arms race. On top of this, space weapons deployment could provoke both horizontal and nuclear proliferation amongst states that are not capable of entering such a space weapons race but wish to respond to the threat.

Despite the PEIS’s claims, various weapons components deployed under Missile Defence will have offensive capabilities, taking war-fighting to a whole new level, quite literally. Such statements are justified by statements from official US sources, such as the US Space Command’s "Vision for 2020", their "Strategic Master Plan FY06 and Beyond" and the USAF Doctrine Document 2-2.1 "Counterspace Operations".

Nuclear proliferation and a space arms race would have considerable, long-lasting effects on arms reduction efforts and international stability and, from the perspective of the PEIS, present a genuine threat to the Earth’s environment through the production of nuclear weapons, the creation of space debris and the possible use of nuclear weapons.

Other issues

The exhaust plumes of missile like the Missile Defence interceptor create considerable toxic pollution which is having an under-rated and very important long-term effect on the Earth’s Ozone Layer. Such effects are to be seen increasingly over the coming years and could have a massive environmental and social impact in the near future. Missile Defence developments will expand the amount of rockets being sent into space and exacerbate this problem.

Yorkshire CND considers it worth emphasising too that the Missile Defence system is currently costing the US taxpayer something in the region of $9 billion every year and that this is likely to rise as deployment of more and more complicated, high-tech systems takes place, alongside maintenance of the current set-up. This amount of money could be diverted so that further cuts in health care, education and public services budgets would not be necessary. The money could be used too for broader, longer-term, more realistic, sustainable security efforts such as the cancellation of third world debt or the provision of food, water, shelter and education to some of the world’s poorest people.

Yorkshire CND asks that our concerns be taken seriously and considered properly. The PEIS has offered itself three options, none of which is sufficient. As we understand it, the "no action" option simply allows for no change in current developments and the continuation of the project. If this is to be the ultimate step that the MDA is prepared to take then it implies a bias towards the outcome of this PEIS study by not allowing for the possibility that the Missile Defence system is too environmentally destructive to continue with.

The Missile Defence system is indeed a hugely expensive, dangerous and, on many levels, environmentally destructive system that is absorbing funds that could be put to better use in the challenge of global security. On these grounds, it should be halted.

 

APPENDIX 1

Fylingdales - Is the Radar Safe?

By Prof. Dave Webb – www.cndyorks.gn.apc.org/fdales

An Information and Safety Booklet given to contractors, new personnel and visitors to the Phased Array Radar (PAR) at RAF Fylingdales in North Yorkshire tells them to keep their mobile phones switched off to protect them from damage from RF power. The booklet also warns that there is a risk of induced RF power causing a spark between car and metal petrol cans and that remote car locking devices may not function. However, it doesn’t mention much about the risk to health of visitors or local residents.

RAF Fylingdales is in the North Yorkshire Moors National Park and has been the home of a US Ballistic Missile Early Warning System (BMEWS) since the Cold War days of the 1960s. The base is run for the US by the RAF and is one of the 3 stations in a chain linked across the North Atlantic. The other stations are Thule in Greenland and Clear in Alaska and the 3 stations provide (in conjunction with the Defense Support early warning satellites) a Tactical Warning/Attack Assessment directly to the US Joint Chiefs of Staff.

The 40-meter high truncated pyramid that forms the PAR has 3 faces each containing an array of 2,560 aerials, transmitting at 420-450 MHz with a total mean power output of 2.5 Megawatts a range of around 3000 miles and is able to operate over a full 360o. The main radar beam is directed to be at least 3o above the horizontal, however side lobes can reach the ground.

At the time of the PAR upgrade to the system (previously it consisted of three mechanically steerable dishes housed in radomes) in 1993, an ElectroMagnetic Radiation (EMR) Survey of the area surrounding Fylingdales was commissioned by the Nuclear Free Local Authorities [1] . The survey was an extension of an earlier report produced in the summer of 1991 and used 23 measurement sites, including moorland paths and tracks, roadside locations and habitations. The survey found maximum field values of about 10Vm-1 which were in fact quite close to the currently accepted international standards developed by the International Commission on Non-Ionizing Radiation Protection (ICNIRP) reference levels of 28-29Vm-1 for the Fylingdales frequency range [2] . The MoD says that "UK safety thresholds are based on NRPB guidelines and not those of ICNIRP" [3] . However, the European Council Recommendation 1999/519/EC requires member states to implement ICNIRP and their power levels are more than ten times lower than NRPB in this frequency range [4] .

Also, there is some question as to the characteristics of the radar beam generated by the thousands of antennae on the PAR. Beams generated by conventional radar are in the form of simple waves, whereas the PAR beam is generated by many overlapping pulses that can strike a person thousands of times in a fraction of a second.

Some investigation into the accepted international standards is required in order to put these results into some kind of context. A recent report on the Physiological and Environmental Effects of Non-ionising Electromagnetic Radiation for the European Parliament [5] states:

"What distinguishes technologically produced electromagnetic fields from (the majority of) those of natural origin is their much higher degree of coherence. This means that their frequencies are particularly well-defined, a feature that facilitates the discernment of such fields by living organisms, including ourselves. This greatly increases their biological potency, and ‘opens the door’ to the possibility of frequency-specific, non-thermal influences of various kinds, against which existing Safety Guidelines – such as those issued by the International Commission for Non-ionising Radiation Protection (ICNIRP) - afford no protection. For these Guidelines are based solely on consideration of the ability of radio frequency (RF) and microwave radiation to heat tissue, and of extremely low frequency (ELF) magnetic fields to induce circulating electric currents in the interior of the body, both of which are known to be deleterious to health, if excessive."

The report points out that the frequency-specific sensitivity of living organisms to ultra-low intensity microwave radiation was discovered over 30 years ago in Russia and there the exposure guidelines are approximately 100 times more stringent that those of ICNIRP. It also notes that some symptoms have been reported in epidemiological studies involving humans, animals and plant life connected with a radar operating at 154-162MHz, with a pulse repetition frequency of 24.4Hz - at a location where the intensity of the emitted radiation is comparable to that typically found at 150m from a base-station. Additional effects include [6] :

  • Depressed nocturnal melatonin levels in cattle [7] .
  • Less developed memory and attention span (as well as decreased endurance of their neuromuscular apparatus) of children living within a 20 km radius of the radar, subject to a maximum exposure of 0.00039 W m-2.
  • A six-fold increase in chromosome damage in cows exposed to a likely maximum intensity of 0.001 W m-2.

(The cited field intensities are estimated from information on the electric field intensity as a function of distance from the radar installation [8] ).

The Fylingdales radar operates by emitting a series of pulses and additional, perhaps more serious, problems may arise at frequencies around 17 Hz. As mentioned in the STOA report, this lies in the range of beta brain-wave activity and is close the frequency of a flashing visible light that can provoke seizures in people with photosensitive epilepsy. It is also the modulation frequency at which "there is a maximum in the expression of calcium ions from brain cells when they are irradiated with amplitude modulated, low intensity RF radiation over a wide range of carrier frequencies" and "any interference … could well undermine the integrity of the whole nervous system, although the extent to which this actually occurs is, at present uncertain, owing to a lack of the necessary research." The pulse repetition frequency of the radar is thought to be 27 pulses per second (at least, this was the documented frequency of the previous system [9] ) and it is not known whether there are any similar effects at or around this frequency that need to be examined closely.

Concerns about the effects of the electromagnetic radiation effects due to the radar were expressed by Yorkshire CND in its submission to the House of Commons Defence Committee on the upgrading of Fylingdales for the US Missile Defense Program (See First Report of Session 2002-3 Volumes I & II, HC 290-I and HC 290-II, published 29 & 30 January 2003). In response the MoD published for the first time results of emr levels measured around the base from 1991. These records show typical recorded levels of around 0.230 mW/cm2 which is comparable with the reference level suggested by the ICNIRP of 0.225 mW/cm2 for 450 MHz radar signals.

Radar power levels can be quoted as field strengths (V/m) or as power densities (mW/cm2). It is general practice amongst those who want to show how low their emissions are to quote in power density since this is proportional to the square of field strength, and therefore levels that are, say, ten times lower than the limit in volts per metre will be 100 times lower if expressed in mW/cm2.

The maximum recorded levels are around 0.869 mW/cm2 (location 26, Top of outside perimeter fence). This is 33% of the NRPB power density level or 58% of the NRPB electric field level. However, it is 4.3 times the ICNIRP power density level or more than twice the ICNIRP voltage level.

In the report the MoD state:

(para 4 on p. Ev60) "It should be borne in mind that UK safety thresholds are based on NRPB guidelines and not those of ICNIRP..."

In fact the UK has failed to implement legislation based on the European Council Recommendation 1999/519/EC, which requires member states to implement ICNIRP safety thresholds (which are ten times lower than NRPB in the frequency range relevant to Fylingdales).

Cape Cod

In April 2001 the US Air Force agreed to conduct "time-domain measurements" on a similar radar installation (known as PAVE PAWS – Phased Array Warning System) at Cape Cod in the US. Local residents there are concerned about the radar because the area has some of the highest rates of cancer in the state. From 1993 to 1997, nine of the Cape's 15 towns had breast cancer rates at least 15 percent higher than the rest of the state. [10]

Richard Albanese, an Air Force scientist for more than 31 years, and others (including Professor Kurt Oughstun) are worried that the radar's phased wave fronts affect human tissue in ways that aren't yet understood. Albanese is reported as suggesting that the radar station should be shut down or moved and that ''I have to go with the concepts of the medical profession, which say that humans shouldn't be exposed to physical or chemical environments that have not been tested' . in the worst case the PAVE PAWS station could be causing a 21 percent increase in ’malignant disease' rates, a risk that would appear to warrant more study. ''In my experience working with military personnel ... misconceptions and errors tend to become entrenched in the organizational setting and do damage to medical practice'' he wrote. [11]

In a presentation given in February 2002 at the start of a series of experiments to measure the PAVE PAWS radar, Albanese said he has conducted animal testing that has shown animals suffering harm when exposed to phased array radar at levels 1,000 times below the current electrical health standards. [12] The question remains "why has the Air Force classified much of Albanese’s work?"

X-Band Radar

There may be additional problems. The UK government has already agreed that Fylingdales can be upgraded for use in the US missile defense ("Son of Star Wars") system and it is still possible that a new high resolution phased-array X-band radar (XBRs) using high frequencies (5.2-8.5 GHz) and advanced radar signal processing technology may eventually be employed at Fylingdales to improve target resolution [13] . These systems emit a series of electromagnetic pulses over a 50o field of view in azimuth and elevation, and can be rotated to track targets from any direction. When fully operational each system will include a radar mounted on pedestal, will need approximately 30 to 60 personnel to operate and will encompass an area of approximately 7 hectares (17.46 acres) for the radar alone and would need to be surrounded by a 150 m (500-foot) controlled area. [14]

XBRs have an average power of 170 kW and an antenna area of 123 m2, which means a power-aperture product of about 20 million, but they usually incorporate a "thinned" array of only 1/5 of the total possible number of aerial elements (around 81,000) decreases the gain by a factor of 5. In this case more energy goes into the radar beam sidelobes but does produce a narrower beam and provides greater tracking accuracy.

Questions have been raised regarding the possible danger to the health of people living close to these installations. The BMDO insists that the microwave leakage from these high power radars is safe – but independent investigations into possible health hazards need to be made.

The XBR BMDO fact sheet [14] states that "The exposure limits established by [the US standard] ANSI/IEEE C95.1 1999 are used to ensure that public health will not be impacted by EMR emitted from the XBR".

Two major exposure environments are defined: inside and outside a controlled area of radius 150m. Security personnel would control the area to prevent any unauthorized access. It is claimed that outside the controlled area the EMR will be no higher than the power density levels specified in ANSI/IEEE C95.1 1999. The US Missile Defense Agency state that:

"There is a possibility that EMR may effect television reception out to a distance of 4 kilometers (about 2.5 miles) from the XBR and that occasional static may occur in some radios out to 7 kilometers (about 4.3 miles) from the XBR."

Concluding remarks

The radar at RAF Fylingdales in North Yorkshire gives rise to a number of concerns:

  • The effects on health from the electromagnetic radiation need further investigation – a fresh EMR survey of the site is needed to update and re-examine the data collected 8 years ago – especially as the accepted international standards are being challenged in the US and by those concerned about the health effects of mobile phone masts etc.;
  • The Ministry of Defence needs to explain why it insists on referring to NRPB guidelines rather than those of the ICNIRP (recommended by the European Union). Could it be because the Fylingdales radar fails the ICNIRP standards but not those of the NRPB ?
  • More studies are needed on the extent and effects due to the low frequencies around the pulse repetition rate (27 Hz) as these may be particularly harmful to biological organisms;
  • The introduction of a proposed X-band radar would mean an increase in EMR levels possibly resulting in an increased danger to local inhabitants and wildlife.

Much more research is required into the extent of EMR pollution at Fylingdales, the effects of these EM fields at the frequencies encountered and a much more in depth study of the health effects of the proposed X-band radar system.

See also: reports on BBC program - "Health Fears Over RAF Radar"

Notes:

[1] "RAF Fylingdales EMR survey: second phase" by Tim Williams, Elmac Services, August 2, 1993

[2] See "Guidelines for Limiting Exposure to Time-Varying Electric, Magnetic and Electromagnetic Fields (up to 300 GHz)" from ICNIRP at http://www.icnirp.de/documents/emfgdl.pdf

[3] See the House of Commons Defence Select Committee Missile Defence report (Vol.2), Feb 2003

[4] Council Recommendation of 12 July 1999 on the limitation of exposure f the general public to electromagnetic fields (0 Hz to 300 GHz) (1999/519/EC)

[5] "The Physiological and Environmental Effects of Non-ionising Electromagnetic Radiation", by G.J. Hyland, Private Treaty No. EP/IV/A/STOA/2000/07/03.

[6] Science of the Total Environment; Issue No 180, 1996.


[7] "Study of Health Effects of Short-wave Transmitter Station at Schwarzenburg", by E.S. Altpeter et al., University of Berne, Inst. for Social & Preventative Medicine, August, 1995.

[8] "Measurement of the intensity of electromagnetic radiation from the Skrunda radio location station, Latvia", by T. Kalnins et al, Science of the Total Environment 1996, 180:51-56

[9] Jane’s Radar and Electronic Warfare Systems, Second Edition, page 62, 1990-1.

[10] "Radar tower plan rekindles fears" by Richard Higgins, The Boston Globe, 5 March 2001

[11] "Making (Radar) Waves" by Ross Kerber, The Boston Globe, 2 July 2001

[12] "Measured Response" by Kevin Dennehy, Cape Cod Times, 28 February 2002

[ 13] The original plans for US Missile Defense did include a ground based XBR system at Fylingdales, but General Kadish of the US Missile Defense Agency has recently suggested that future XBRs might be based at sea rather than on land.

[14] "X band radar Fact Sheet" from the BMDO - was originally at www.acq.osd.mil/bmdo/bmdolink/pdf/jn0019.pdf but now removed - a copy can be found at www.cndyorks.gn.apc.org/bases/xbandradar.pdf