Stop Wireless 5G  Until Health Canada's Safety Code 6 Is Fixed: A Guide to Why and How  
Frank Clegg  
April O'Donoughue 
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First Edition — February 25, 2022  
Includes link   
to C4ST's 
FACT‐CHECKER 
of Government of 
Canada Webpages! 
see page 112.
We wish to acknowledge with gratitude the help of all of the volunteer editor-critics,  as well as the tireless efforts of scientists and advocates around the world  who give so much of their time to raise awareness of this issue  
and who have inspired us.  
Despite our best efforts, there may be mistakes in this guide.  
All errors are our own.  
Disclaimer  
This document is for general information purposes only. While we endeavour to keep the information up to  date and correct, C4ST and its authors accept no liability or responsibility for any acts or errors, omissions,  misuse, and/or misinterpretation resulting from reliance, in whole or in part, on the information provided herein.  Any reliance you place on the information in this guide is therefore strictly at your own risk.  
This guide may contain copyrighted material which has not been specifically authorized by the copyright  owner. C4ST is making such material available for news reporting, criticism, education, scholarship, and  research, and believes this constitutes a "fair use" of such material as provided for in the Canadian Copyright  Act.  
It may also contain links to third party content, which we do not warrant, endorse, or assume liability for, nor  guarantee the accuracy, relevance, timeliness, or completeness of such content, nor that the website links will  be updated.  
© Canadians for Safe Technology (C4ST)  
This document may be reproduced free of charge as long as acknowledgement is made of the source. 
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Stop Wireless 5G  
until Health Canada's Safety Code 6 is Fixed:  
A Guide to Why and How  
PREFACE............................................................................................................................................7 
1. EXECUTIVE SUMMARY ...............................................................................................................9 
1.1. SUMMARY...............................................................................................................................9 1.2. TOP TEN REASONS WHY 5G SHOULD BE PUT ON HOLD ..........................................................13 
2. AN OVERVIEW OF 5G................................................................................................................15 
2.1. WHAT IS 5G?........................................................................................................................15 2.2. THE ELECTROMAGNETIC SPECTRUM......................................................................................17 2.3. WHAT IS DIFFERENT ABOUT 5G?............................................................................................19 
2.3.1. 5G will be the first cellular network to use millimetre waves (mmWaves).............................19 2.3.2. Higher Cell Density: The industry's solution to the short range of mmWaves.......................20 2.3.3. The Competition: Low Earth Orbit Satellites to blanket the country......................................21 
2.4. WHY IS 5G SO CONCERNING?................................................................................................22 2.5. WHAT ARE THE BENEFITS? ....................................................................................................23 2.6. THE INTERNET OF THINGS (IOT) ............................................................................................24 2.7. WHEN WILL 5G BE ROLLED OUT IN CANADA?..........................................................................24 
3. WHY ARE WE CONCERNED?...................................................................................................26 
3.1. HEALTH EFFECTS (LONG-TERM) ............................................................................................26 3.1.1. There has been no research on the health effects of long-term exposure to 5G..................26 3.1.2. Thousands of peer-reviewed studies show serious adverse health effects of current wireless  
technologies...........................................................................................................................26 3.1.3. A Known Human Carcinogen ................................................................................................29 3.1.4. Children and Other Vulnerable Populations ..........................................................................31 3.1.5. Canadians are already overexposed to microwave radiation................................................33 
3.2. HEALTH EFFECTS (MORE IMMEDIATE): ELECTROMAGNETIC HYPERSENSITIVITY – THE CANARIES  IN THE COAL MINE ................................................................................................................33 3.3. IMPACTS ON WILDLIFE, INCLUDING BIRDS AND POLLINATORS, AND PLANTS.............................35 3.3.1. What we know: The growing evidence ..................................................................................36 3.3.2. Recent Scientific Reviews .....................................................................................................38 3.3.3. State of New Hampshire Report............................................................................................39 
3.3.4. Canada has NO regulations to protect flora and fauna from RF radiation. What are we  waiting for?.............................................................................................................................41 3.3.5. Meanwhile, plans are underway for the Internet of Underwater Things (IoUT).....................42 3.4. A MAJOR CONTRIBUTOR TO CLIMATE CHANGE AND POLLUTION..............................................43 3.4.1. 5G is not sustainable – plain and simple...............................................................................43 3.4.2. Large consumers of energy – from production to usage.......................................................44 3.4.3. E-Waste will increase substantially with 5G ..........................................................................46 3.4.4. High social and environmental costs .....................................................................................46 3.4.5. Space Junk ............................................................................................................................46 3.5. RISKS TO PERSONAL AND BUSINESS PRIVACY .......................................................................47 3.6. GRAVE SECURITY RISKS .......................................................................................................48 3.7. CONTRAVENTION OF HUMAN RIGHTS.....................................................................................50 3.8. DECREASED ABILITY TO FORECAST THE WEATHER AND MONITOR THE CLIMATE, AND A THREAT  TO ASTRONOMICAL OBSERVATION.........................................................................................51 3.9. MAJOR RISK TO AVIATION SAFETY.........................................................................................52 3.10. INCREASED ECONOMIC BURDEN............................................................................................53
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4. SCIENTISTS AND DOCTORS HAVE BEEN WARNING GOVERNMENTS FOR YEARS.........54 
4.1. THE INTERNATIONAL EMF SCIENTIST APPEAL TO THE UN (ONGOING).....................................54 4.2. SCIENTISTS' 5G APPEAL TO THE EUROPEAN UNION (ONGOING)..............................................54 4.3. CONSENSUS STATEMENT OF UK AND INTERNATIONAL MEDICAL AND SCIENTIFIC EXPERTS AND  
PRACTITIONERS ON HEALTH EFFECTS OF NON-IONISING RADIATION (NIR) (ONGOING)...........55 4.4. INTERNATIONAL APPEAL TO STOP 5G ON EARTH AND IN SPACE (ONGOING) ............................56 4.5. UNITED STATES OF AMERICA NATIONAL 5G RESOLUTION.......................................................56 4.6. APPEALS BETWEEN 1998 AND 2014......................................................................................57 
5. WHO REGULATES WIRELESS DEVICES, CELL ANTENNAS, AND THE USE OF THE  SPECTRUM IN CANADA?..........................................................................................................58 
5.1. THE SPECTRUM AUCTIONS – IS THE GOVERNMENT IN A CONFLICT OF INTEREST? ..................58 5.2. ANTENNA SITING AND PUBLIC CONSULTATION – IS THIS CANADIAN DEMOCRACY?...................59 5.3. ANTENNAS MUST COMPLY WITH ENVIRONMENTAL LEGISLATION. . . BUT THERE ARE NO  
GUIDELINES TO PROTECT OUR NATURAL ENVIRONMENT FROM RF RADIATION ..........................60 5.4. FOR HEALTH CONCERNS, ISED DEFERS TO HEALTH CANADA’S SAFETY CODE 6 .....................60 5.5. DOES ANYONE MONITOR THE RF RADIATION EMITTED BY THE INSTALLATIONS?........................61 
6. SURELY HEALTH CANADA HAS SAFETY GUIDELINES TO PROTECT ITS CITIZENS? .....63 
6.1. SAFETY CODE 6 – HEALTH CANADA'S EXPOSURE GUIDELINES ...............................................63 6.2. IS HEALTH CANADA FULFILLING ITS MANDATE?.......................................................................65 6.2.1. Health Canada’s guidelines for RF radiation, based on thermal effects, are obsolete .........66 6.2.2. Safety Code 6 does not protect Canadians' health. ..............................................................67 6.2.3. Health Canada has never completed a proper review. .........................................................68 6.2.4. Health Canada's decisions are not based on all of the current scientific evidence...............70 6.2.5. Health Canada relies on biased organizations when setting its exposure guidelines...........70 6.2.6. Health Canada's process to update Safety Code 6 is deeply flawed....................................73 6.2.7. Health Canada's guidelines are behind other countries........................................................75 6.3. REPORT OF THE HOUSE OF COMMONS STANDING COMMITTEE ON HEALTH (HESA) IGNORED .77 6.4. WHY IS HEALTH CANADA NOT ACTING?..................................................................................78 6.4.1. Not one of the recommendations made by the House of Commons Standing Committee on  Health (HESA) in 2015 has been fully implemented. ............................................................78 6.4.2. How much more evidence does Health Canada need? ........................................................79 6.4.3. Health Canada’s track record has been poor in responding to other harmful agents...........80 
7. PERVASIVE CONFLICTS OF INTEREST ..................................................................................81 
7.1. INTERNATIONAL COMMISSION FOR NON-IONIZING RADIATION PROTECTION.............................81 7.2. WORLD HEALTH ORGANIZATION (WHO) AND ITS EMF PROJECT ............................................84 7.3. INDUSTRY INFLUENCE ...........................................................................................................85 7.4. MEDIA COVERAGE ................................................................................................................86 
8. DO WE REALLY NEED 5G NOW?.............................................................................................87 
8.1. WHY THE RUSH?...................................................................................................................87 8.2. THE SCIENTIFIC DECISION IS CLEAR ......................................................................................88 
9. SAFER ALTERNATIVES EXIST: WIRED IS BETTER. ..............................................................90 
9.1. WIRED VS WIRELESS ............................................................................................................90 9.2. DO WE NEED WIRELESS FOR 911? .......................................................................................94 9.3. FIBRE OPTICS TO THE PREMISES (FTTP) FOR ALL CANADIANS...............................................95 9.4. REMOTE AREAS DO NOT HAVE TO SETTLE FOR SATELLITE BROADBAND.................................96 9.5. TAKING CONTROL: SOME COMMUNITIES ARE BUILDING THEIR OWN FIBRE INFRASTRUCTURE 96
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10. ACTIONS TAKEN BY OTHERS AROUND THE WORLD ..........................................................99 
10.1. GOVERNMENT ACTIONS ........................................................................................................99 10.2. LEGAL ACTION ....................................................................................................................102 10.3. THE INSURANCE INDUSTRY PROTECTS ITSELF FROM CLAIMS................................................104 10.4. THE TELECOM INDUSTRY IS AWARE OF THE RISKS ................................................................106 
11. CONCLUSION...........................................................................................................................108 
12. IT DOESN'T HAVE TO BE THIS WAY: TAKE ACTION...........................................................110 
12.1. INTRODUCTION (OR TO RECAP) ............................................................................................110 12.2. WHAT WE NEED .................................................................................................................111 12.3. PROTECT YOURSELF AND YOUR FAMILY ..............................................................................115 12.4. RAISE AWARENESS.............................................................................................................117 12.5. STAND UP AGAINST THE INSTALLATION OF ANTENNAS IN YOUR NEIGHBOURHOOD ................118 12.6. THE SINGLE MOST IMPORTANT THING THAT YOU CAN DO: PUSH THE FEDERAL GOVERNMENT  
TO PROTECT ITS CITIZENS...................................................................................................123 12.6.1. What We Want Our Member of Parliament (MP) to Do ......................................................123 12.6.2. Steps You Can Take to Get Your MP to Act .......................................................................124 12.6.3. Meeting with Your MP..........................................................................................................125 12.6.4. Other Federal Elected Officials to Write to ..........................................................................127 12.7. ASK YOUR PROVINCIAL REPRESENTATIVE TO PROTECT ITS CITIZENS...................................128 
13. WHO WE ARE...........................................................................................................................129 
APPENDICES..................................................................................................................................130 
APPENDIX 1 – CELLULAR ANTENNAS IN CANADA ........................................................................131 APPENDIX 2 – SOURCES OF INFORMATION .................................................................................133 APPENDIX 3 – CANADIAN ADVOCACY GROUPS RAISING AWARENESS..........................................140 APPENDIX 4 – SCIENTIFIC EVIDENCE FOR HARM TO HEALTH.......................................................141 APPENDIX 5 – SCIENTIFIC EVIDENCE FOR HARM TO NON-HUMAN LIFE (WILDLIFE, BIRDS, INSECTS, 
POLLINATORS, TREES AND PLANTS) ....................................................................................143 APPENDIX 6 – PUBLICATIONS ON ENERGY CONSUMPTION RELATED TO INFORMATION AND  COMMUNICATIONS TECHNOLOGY ........................................................................................147 APPENDIX 7 – EVIDENCE IGNORED BY HEALTH CANADA .............................................................150 APPENDIX 8 – ACTION TOOLS....................................................................................................155 APPENDIX 9 – URGENT APPEAL TO THE GOVERNMENT OF CANADA ............................................160
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"With EMF, we know that exposure of some kind is  
going to have its consequences biologically.  
And there will be a segment of the population that will succumb at some level.  
What we have to do is decide, as a society,  
what is the level at which we want to set that. 
And that's a political decision.  
I think the scientific decision is clear: 
that the standards have to be looked at again and have to be reset."  
-- Martin Blank, PhD  
Former Associate Professor, Columbia University,  
Department of Physiology and Cellular Biophysics (deceased)  
(from an August 2009 lecture entitled Electromagnetic Fields and Health Risk)
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Preface  
While the world is finally waking up to the reality of climate change, another problem is  growing at an alarming rate. And while it has been visible on the radar screens of scientists  around the world for some time, our government seems to be on automatic pilot.  
It started off gradually. Then, more and more cell towers started popping up, disfiguring the  landscape, and creeping closer to homes.  
Communities across Canada have been opposing them. At first, for esthetic reasons… then  when they search for information on how to stop them, they discover the health risks.  The antennas on these towers give off radiation -- and for the past 20 years, scientists have  been warning that this radiation is harmful. Hundreds of high-quality peer-reviewed studies  by credible and respected scientists point to cancer, DNA damage, neurodegenerative  diseases, infertility, and more… plus serious effects on wildlife, birds, bees and trees.  
“Surely our government would not allow this?” “How could this be?” they ask.  
Then comes the second awakening; citizens and their municipalities have little say.  It is a federal matter.  
As citizens exercise their right to be consulted, they discover that the process favours the  telecommunications company. The consultation is simply window-dressing. The only way a  tower has been stopped is by local community members organizing a vocal resistance. In  some cases a compromise location is found, but only after significant resistance from the  community and local politicians.  
As municipalities try to exercise their duty to protect the well-being of their citizens, they  discover that there is little that they can do.  
From Vancouver Island to Newfoundland, so many have gone through this heart-breaking  experience and still are. The struggle does not stop at cell towers. RF radiation is the by product of all wireless devices and antennas. People have been fighting Wi-Fi in schools,  the forced installation of “smart” meters, small cell antennas...  
What has our government been doing?  
Not much. Health Canada’s exposure guidelines (Safety Code 6) are obsolete and do not  protect Canadians. Industry Canada’s decisions regarding cell tower siting still do not take  into account the outcomes of consultations, i.e., the peoples’ will. And Environment Canada  still has no guidelines to protect our flora and fauna from RF radiation. With the challenges  already faced by many species in terms of habitat loss, chemical pollution and climate  change, how will RF radiation impact them?  
For the past 20 years, Health Canada has refused to consider the large body of research  that proves that RF radiation has harmful effects at levels far below Safety Code 6.  
For the past 20 years, the industry keeps repeating the same mantra: “The jury is still out;  more research is needed”. (Remember the tobacco playbook?)  
With 5G the situation is about to get a whole lot worse. 
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The telecom industry is ramping up production in its “race for 5G”, expanding and densifying  its infrastructure of towers and small cell antennas, while their competition is launching  thousands of low orbiting satellites. Companies are rushing to join the Internet of Things  (IoT) bandwagon… implanting chips into everything from toothbrushes and diapers, to  washing machines and cars.  
Slick marketing of gadgets, and some truly useful tools, have ensured a willing, though  misinformed, customer base – even though it is clear that the IoT is being driven by the  potential to make money rather than by a desire to meet real needs.  
Not only are there virtually no government regulations to exercise control over this rollout,  our government seems to be leaning towards paving the way by favouring wireless  approaches over wired.  
There are better alternatives. We can have many of the benefits this technology promises  through fiber-optic technology, a much safer, faster, and more secure approach.  
This is not about allowing a harmful product that a consenting adult  
may choose to use, or not, like smoking in your home.  
This is about allowing the 24/7 irradiation of all living things  
– our families, our children, our pets, wildlife, pollinators, trees and other plants –  whether they consent to it or not,  
whether they understand the consequences or not. 
Are the benefits worth the risks?  
What can we do about it? Is it really too late?  
What are other jurisdictions doing about it?  
“How far should we go as a society toward locking ourselves into  
a technological system that risks public health for the sake of a plethora  of wireless applications, many of which are amusements,  
and business models that add risk and instability to the economy?  
It seems to be time to address these questions seriously.”  
– Timothy Schoechle, PhD, Re-Inventing Wires:  
The Future of Landlines and Networks  
This is a complex issue to communicate. It’s a story filled with scientific facts on the one  hand, and on the other, politics, conflicts of interest, lack of transparency, and a trillion-dollar  industry. And caught in the middle are the people and the environment.  
This Guide is intended to help you navigate this topic.  
We hope it will serve as a reference, a wake-up call, and a call to action.  Our hope is that once Canadians and our Members of Parliament have a better  understanding of the risks of wireless technologies to our health, our environment and our  security, and of the scope of the rollout of 5G and the Internet of Things, we will all feel  compelled to act.  
Chapter 12 provides examples of actions you can take. If you take action, please keep us informed at  [email protected]. All suggestions are welcome. Please send them to [email protected].  
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1. Executive Summary  
1.1. Summary  
More than just an upgrade, 5G, the next generation of wireless technologies, is being  rolled out rapidly across Canada. While earlier generations focused on cellular  communication, the vision for 5G is to connect much more than people and phones. It is  centered around the Internet of Things (IoT) – machine-to-machine communication.  
5G promises extremely fast data speeds and much lower latencies (network delays) than  previous generations. To do this, it will use greater bandwidth and new technologies.  Earlier generations of cellular networks in Canada used frequencies below 2.6 GHz.  5G will use those same frequencies and the recently auctioned 3.5 GHz, plus it will add  the “extremely high frequency” millimetre waves (mmWaves) at 26 GHz and higher.  
To get around the shorter range of the mmWave band, 5G will require a vast additional  infrastructure, including more towers and hundreds of thousands of small cell  antennas located very close to homes and businesses.1 Lamp posts, hydro poles, sides  of buildings and many other locations are candidates to host small 5G cell antennas.  
At the same time, the competition is launching tens of thousands of low orbit satellites to  provide Internet service to every inch of the planet.  
Why are we concerned?  
There has been no research on the health effects of long-term exposure to mmWave  radiation. (We are "flying blind,” to quote a U.S. senator2).  
We do have considerable evidence about the harmful effects of the microwaves used  in 3G, 4G and LTE (the lower frequency bands that will also be used in 5G).  
Hundreds of scientists specialized in the field have been warning governments for  years that this type of radiation is harmful to humans and the environment. Over the  last 20 years, more than 40 appeals and resolutions calling for more protective standards  from radiofrequency (RF) radiation have been endorsed by hundreds of EMF researchers  and physicians. See Chapter 4 for a list of these appeals. 
We know from more than 200 scientists representing over 40 countries, who have published  more than 2,000 studies in this field, that there is strong evidence of harm to humans and to  the environment from exposure to the frequencies used in other generations of wireless  technology (2G, 3G, 4G, LTE) that power our commonly used wireless devices such as cell  phones, cordless phones and cell antennas.  
  
1 There are currently 730,442 transmitters (48,288 towers) in Canada according to the Innovation, Science  and Economic Development (ISED) Spectrum Management System database (as of Nov. 2, 2021). 5G  network infrastructures will require a much greater cell density. http://sms-sgs.ic.gc.ca/eic/site/sms-sgs prod.nsf/eng/h_00010.html - https://www.itworldcanada.com/article/everythingyou-need-to-know-about 5g/416498 
2 US Senator Blumenthal Raises Concerns about 5G Wireless Technology Health Risks at Senate Hearing,  Feb 6, 2019. https://www.youtube.com/watch?v=ekNC0J3xx1w&feature=youtu.be
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The rollout of 5G and the IoT will result in massive increases of constant exposure to  radiofrequency (RF) radiation – without the informed consent of Canadians. There will be  no place for people – and wildlife, including pollinators and trees – to escape from this  harmful environmental pollutant.  
See section 1.2, for our Top Ten Reasons why 5G should be put on hold.  The situation in Canada  
The federal Ministry of Innovation Science and Economic Development (ISED)  regulates wireless devices, cell antennas and the use of the spectrum in Canada.  ISED requires that all wireless devices and antennas comply with Health Canada’s Safety  Code 6. Public consultation is required for cell towers; however, citizens cannot oppose  them on the basis of health concerns. And for towers under 30 metres, the wider  community is not notified of the consultation. As for the small cell antennas placed on “non tower structures” such as lamp posts, hydro poles or on (or in) buildings, public notification  is not required at all. Hundreds of thousands of small cell antennas are being installed  across Canada, close to people’s homes without their knowledge and consent.  
Health Canada's Safety Code 6 is obsolete and does not protect Canadians.  
Safety Code 6 guidelines “establish safety limits for human exposure to radiofrequency (RF)  fields”.3 Since 1979, these guidelines for cell antennas have had only minor changes and  are still based on a 1929 assumption4,5 that thermal effects (heating) are the only  “established” adverse effects.6 A significant amount of peer-reviewed, published, scientific  evidence now points to harm from non-thermal effects at well below these limits.7 Health  Canada’s track record has been poor in responding in a timely manner to other harmful  agents such as asbestos, Bisphenol-A (BPA), cigarette smoking, dioxins, lead, mercury,  thalidomide and urea formaldehyde insulation.  
Because 5G frequencies fall within Health Canada’s Safety Code 6 guidelines, Health  Canada has taken the position that the technology is safe for humans, even though there  has been no research on the health effects of long-term exposure to mmWaves and the  new 5G technologies.  
Environment Canada has no guidelines to protect our flora and fauna from RF radiation.  
Pervasive conflicts of interest  
Health Canada relies on biased organizations when setting its exposure guidelines – in  particular the International Commission on Non-Ionizing Radiation Protection (ICNIRP). This  organization and several others have come under criticism for biases and conflicts of  interest. Chapter 7 delves into some of these.  
  
3 https://www.canada.ca/en/health-canada/services/publications/health-risks-safety/limits-human-exposure radiofrequency-electromagnetic-energy-range-3-300.html 
4 https://www.magdahavas.com/wp-content/uploads/2010/07/Cook_1980_early_research.pdf 5 www.hc-sc.gc.ca/ewh-semt/consult/_2014/safety_code_6-code_securite_6/final_finale-eng.php. Section 2.  MAXIMUM EXPOSURE LIMITS, paragraph 2 - first sentence. 
6 At the lower part of the radiofrequency range, which is not used by everyday wireless devices, Safety Code 6  also considers peripheral nerve stimulation to be an established effect.  
7 See sections 3.1.2, 6.2.1 and 6.2.2 of this guide for references. Here are a just a few:  docs.c4st.org/Studies/original 
references_of_over_200_scientific_studies_showing_potential_harm_at_levels_below_safety_code_6.pdf;  and https://www.saferemr.com/2014/08/why-we-need-stronger-cell-phone_43.html 
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Do we really need 5G?  
In addition to health concerns, experts are challenging the business case of wireless  networks. As industry continues its race to install the infrastructure for their 5G networks, we  believe it is time to stop and consider the costs.  
Are the benefits of widespread wireless 5G worth the risk to our health, our environment,  our privacy, and our security? According to hundreds of independent scientists, the answer  is a clear "no".  
As Dr. Martin Blank, a leading expert on the health effects of electromagnetic fields, said:  
"With EMF, we know that exposure (...) is going to have its consequences biologically.  And there will be a segment of the population that will succumb at some level.  
What we have to do is decide, as a society, what is the level at which we want to set that.  And that's a political decision.  
I think the scientific decision is clear:  
that the standards have to be looked at again and have to be reset."
Safer alternatives exist  
There is a cheaper, faster, greener, more reliable and safer way to provide this next wave of  technology, namely fibre-optic technology – fibre to and through the premises (FTTP). 
Around the world, people are speaking out.  
∙ Some governments are beginning to listen. Many jurisdictions are stopping the  rollout of 5G technology. Some have passed legislation or taken other actions to  protect their citizens’ health from exposure to wireless radiation.  
∙ Many citizens have turned to the courts. And there have been breakthroughs in  case law in other countries.  
Of particular note: the recent decision by the US Federal Court that the FCC's  decision to retain its 1996 safety limits for human exposure to wireless radiation was  "arbitrary and capricious" and ordering it to provide "a reasoned explanation" for its  decisions, and to "address the impacts of RF radiation" on people and on the  environment. It also stated that the commission cannot rely on agencies like the FDA if  the FDA's conclusions are provided without explanation.  
This is significant because Health Canada is guilty of the same: It bases its safety  limits on the same obsolete assumption that only heating causes harm, does not  provide a reasoned explanation for its decisions, and relies on other organizations that  do not provide full, reasoned justifications.  
See the section 10.2 for more on this historic ruling.  
∙ The insurance industry is definitely taking no chances. It has taken steps to  protect itself from future claims.  
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It doesn’t have to be this way: Take action  
Join Canadians for Safe Technology.  
Suggested actions you, as a Canadian, can take are included in chapter 12.  It is time for our Government to…  
∙ update Safety Code 6. Set up a truly independent panel with appropriate expertise to  review the scientific evidence, including non-thermal, biological effects of RF radiation.  
∙ establish guidelines to protect wildlife and the environment from RF radiation.  
∙ protect individual rights, taking into account sensitive populations (children, pregnant  women, immune-compromised, electrosensitive, people who are ill, the elderly, etc.).  
In the meantime, we urge the federal government to take the following actions now,  before it is too late.  
∙ Stop the rollout of 5G, especially “small cell” antennas and towers near homes.  ∙ Stop the auction of the extremely high frequency spectrum (planned for early 2024). 
∙ Launch an awareness campaign so Canadians can take steps to protect themselves  and their children from the current levels of radiofrequency/microwave radiation.  
∙ Require that the telecommunications and wireless technology industries prove that  their products are safe for Canadians and the environment.  
∙ Complete an economic analysis of the total potential economic burden of 5G.  
∙ Invest in full fibre-optic broadband coverage across Canada (FTTP). Favour wired  technologies rather than wireless and satellite options.  
We recommend the adoption of the following principles:  
∙ The Precautionary Principle, which states that where there are threats of serious or  irreversible damage to the environment or to human health, lack of full scientific certainty shall  not be used as an excuse for postponing the adoption of measures to prevent such  environmental and health degradation.  
∙ Pollution prevention, acknowledging that it is less expensive and more effective to prevent  damage to the environment and to human health, than to manage or cure this damage.  
∙ Communities’ right to know about health and environmental risks and to participate  in making decisions that affect their health.  
Indeed, this is the tradition of public health, a tradition which in Canada, through the  Supreme Court, has given municipalities the authority to ban pesticides.8 
In the post-COVID-19 economic recovery plan, let’s make sure that decisions put people  and our environment first.  
  
8 Ashbury FD, Sullivan T. Review of Misconceptions about the Causes of Cancer. Chronic Dis Can  2004;25:152-53. 
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1.2. Top Ten Reasons Why 5G should be put on hold  
Please see Chapter 3 for a detailed review of the evidence and supporting references.  
1. There is scientific proof that radiation from wireless technologies will have  significant harmful impacts on human health in the long term.  
a. Hundreds of high-quality peer-reviewed studies show that exposure to  radiation from current (pre-5G) wireless technologies causes serious adverse  health effects.  
b. 5G will use those same frequencies, plus it will employ new technologies and  add the millimetre wave (mmWave) band to the mix. There has been no  research on the long-term effects to ensure that 5G technology is safe.  
c. Published evidence demonstrates that RF radiation can cause cancer.  d. Children and other vulnerable populations are more seriously impacted.  e. Scientists have been warning our politicians for years.  
f. Health Canada's Safety Code 6 does not protect Canadians.  
2. Some people experience immediate health effects – Electromagnetic  Hypersensitivity (EHS): The Canaries in the Coal Mine  
a. As with other environmental exposures, some people are more susceptible  (sensitive or intolerant) and overtly affected by wireless technologies.  
b. Surveys conducted in several countries between 1998 and 2007 estimated  that 3%-13% or more of the population experience symptoms of EHS.  c. Many are being mis- or undiagnosed because the medical community is not  well informed about the symptoms and underlying causes, namely  
overexposure to wireless devices and antennas.  
3. Wireless technologies impact wildlife, including birds and pollinators, and  plants.  
a. Research has demonstrated adverse effects of radiofrequency radiation on the  environment including wildlife, such as birds, amphibians, insects, fish,  mammals, and plants. 
b. Studies show that RF radiation can impact the navigation abilities of birds and  bees; and cause nest and site abandonment, plumage deterioration,  
locomotion problems, reduced survivorship and death in wild nesting birds.  
4. 5G and other wireless networks and technology are major contributors to  climate change and pollution, and are not sustainable.  
a. Wireless technologies consume at least 10 times more power than wired  technologies. A 5G base station is expected to consume roughly three times  more power than a 4G base station. And 5G will require far more base  stations.  
b. 5G will cause a substantial increase of e-waste since devices currently used  will become obsolete. Only 20% of e-waste is recycled today.  
c. Most concerning is the exponential growth of the Information and  
Communication Industry (ICT), and its footprint relative to the total worldwide  footprint. Greenhouse gas emissions from smart phones alone jumped 730% in  absolute terms in just 10 years (2010-2020).  
d. If the wireless industry were a country, it would be the fifth largest consumer of  energy in the world. 
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5. 5G networks will increase the risks to individual and business privacy by  transmitting massively more data wirelessly.  
a. Sensitive information can easily be transferred, leaked or hacked in a wireless  network.  
b. 5G networks will allow massive amounts of data to be transmitted wirelessly,  providing more opportunities to collect, process, harvest and use it for  commercial, or for nefarious, purposes.  
6. There are significant cybersecurity risks with 5G. 
a. Wireless networks are less secure, more prone to hacking than wired systems.  
7. Basic human rights are being infringed since citizens cannot oppose a cell  tower on the basis of health concerns. Small cell antennas do not even require  public notification, nor do low earth orbit satellites.  
Hundreds of thousands of 5G small cell antennas are being installed across Canada  on lamp posts, hydro poles and other structures close to people's homes and  workplaces, without their knowledge and consent. 
a. Public consultation is required for cell towers; however, citizens cannot oppose  them on the basis of health concerns. And for towers under 30 metres (98  feet), the wider community is not even notified of the consultation, i.e., those  living at a distance of more than three times the height of the tower.  
b. Notification is not required at all for: 
∙ Non-Tower Structures: antennas on (and in) buildings, water towers,  lamp posts, bus shelters, etc. may be installed without notifying or  
consulting the public, provided that the height of the structure is not  increased by more than 25%;  
∙ Existing Towers: modifications may be made to facilitate sharing or the  addition of antennas, provided that the total height increase is no  
greater than 25% of the height of the initial installation. 
8. Scientists have warned that 5G technology will interfere with critical satellite  data, resulting in a 30% reduction in weather forecast accuracy, and  decreasing the ability to monitor the climate. NASA and the US National Oceanic  and Atmospheric Administration agree. It could also interfere with radar altimeters  posing a major risk to aviation safety. The deployment of tens of thousands of  satellites will cause unprecedented light pollution, hindering astronomical  observation.  
9. Concerns have been raised about the economic burden of increased health care  costs, lost productivity, financial impacts of security and privacy breaches, damage  caused by the degradation of weather forecast accuracy, and environmental damage.  
10. Better alternatives exist. Fibre and wired connections are . . .  ∙ safe (do not emit RF radiation )  
∙ 100 times faster and more reliable  
∙ far less vulnerable to security and privacy breaches  
∙ more reliable in a disaster  
∙ consume 10 times less energy; do not rely on rare minerals. 
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2. An Overview of 5G  
2.1. What is 5G?  
5G is the next generation of wireless technologies, the planned successor to the 4G  network.  
It is being designed to provide greater capacity for wireless networks, to deliver extremely fast data speeds and much lower latencies (network delays) than previous generations.  Industry promises to provide us with an entirely new level of connectivity with the Internet of  Things. From autonomous vehicles to smart cities and so-called fibre-over-the-air, 5G  intends to be at the heart of the future of communications.  
How will 5G achieve this?  
5G will use:  
∙ greater bandwidth – a range of frequencies from 600 MHz to 100 GHz – and  ∙ new technologies: massive MIMO (massive multiple inputs and outputs), advanced  beamforming, higher cell density, higher spectral efficiency, OFDM (orthogonal  frequency-division multiplexing), time division duplexing.  
While 4G and earlier generations of cellular focused on cellular communication, the vision  for 5G is to connect much more than phones.  
This has become clear in the latest set of 5G standards codified by the 3rd Generation  Partnership Project (3GPP), the industry group that establishes the standards for cellular  networks.9 3GPP finalized Release 16 on July 3, 2020. While earlier releases of the 5G  standards focused on the core of 5G as a generation of cellular service, Release 16 laid the  groundwork for new services that have never been addressed by cellular before.10  
For example (excerpt from an article published in IEEE Spectrum in 2020):  
∙ Sidelinking: a new technique that will allow 5G-connected vehicles to communicate  directly with one another (V2X, short for “Vehicle to Everything”), rather than going  through a cell-tower intermediary. This technique can theoretically apply to any two  devices that might need to communicate directly rather than go through a base station  first. For example: Internet of Things installations, factory robots, etc.  
∙ Location Services: In past generations of cellular, three cell towers were required to  triangulate where a phone was by measuring the round-trip distance of a signal from  each tower. But 5G networks will be able to use the round-trip time from a single tower  to locate a device. That’s because massive MIMO and beamforming allow 5G  antennas to send precise signals directly to devices, and so the network can measure  the direction and angle of a beam, along with its distance from the antenna, to locate it.  
  
9 The 3rd Generation Partnership Project (3GPP) https://www.3gpp.org/about-3gpp/about-3gpp.  The International Telecommunication Union Radiocommunication Sector formally approved the 3GPP 5G  technology as International Mobile Telecommunications-2020 (IMT-2020) 5G standard at the ITU-R Working  Party 5D #35 meeting, July 9, 2020 https://www.huawei.com/en/news/2020/7/3gpp-itu-imt-2020-5g-standard 10 Michael Koziol, IEEE Spectrum, "5G Just Got Weird: Industry group 3GPP takes 5G in new directions in  latest set of standards", August 7, 2020 – https://spectrum.ieee.org/tech-talk/telecom/standards/5g-release-16
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∙ Private Networks: 5G will incorporate millimetre waves, which are higher frequency  radiowaves (30 to 300 GHz) that don’t travel as far as traditional cell signals.11 With  millimetre waves, it will be possible to build a network just for an office building, factory,  or stadium. At those scales, 5G could function like Wi-Fi networks.  
∙ Unlicensed Spectrum: Release 16 expands 5G into unlicensed spectrum in the 5 and  6 GHz bands. Unlicensed spectrum could be key for private networks that, similar to  Wi-Fi networks, use a specific spectrum without having to go through the process of  licensing a frequency band.  
∙ Release 17 Will “Extend Reality”: In December 2019, the scope of Release 17 was  decided. Among the items to be included: extended reality (alternate reality and virtual  reality technologies), and to study the possibility of using frequencies in the 52 to 71  GHz range, far higher than anything used in cellular today. The schedule for Release  17 anticipates completion in 2022.  
For more information on the technologies, read this article by Tom Li, IT World Canada  "Everything you need to know about 5G", April 11, 2019 --  
https://www.itworldcanada.com/article/everything-you-need-to-know-about-5g/416498 
Here is a short video from IEEE Spectrum, a magazine edited by the Institute of Electrical  and Electronics Engineers: https://www.youtube.com/watch?v=GEx_d0SjvS0 
For more information on the latest release of the 5G Standards, read this article by  Michael Koziol, IEEE Spectrum, "5G Just Got Weird: Industry group 3GPP takes 5G in new  directions in latest set of standards", August 7, 2020 –  
https://spectrum.ieee.org/tech-talk/telecom/standards/5g-release-16 
Here is a link to the various releases of the standards by 3rd Generation Partnership  Project (3GPP) https://www.3gpp.org/DynaReport/FeatureListFrameSet.htm 
5G vs 4G  

4G/LTE  
in Canada* 
5G currently  
in Canada**
5G  
promises 



Download speed (max average) 
80 Mbps 
112 Mbps 
10 Gbps 



Latency in milliseconds  
measured as Round Trip Time (RTT)  Note: blink of an eye = 100 to 400 ms 
38-41 ms 

<1ms 



Frequencies used  
(1 GHz = 1000 MHz) 
600 MHz to  
2.5 GHZ
600 MHZ to  
6 GHz
600 MHz to  
100 GHz




* Data rates for 4G: Opensignal. Canada - Mobile Network Experience Report – Feb 2020  
https://www.opensignal.com/reports/2020/02/canada/mobile-network-experience 
The three large Canadian operators have surpassed the 90% mark in 4G availability.  
** Data rates for 5G: Opensignal. Canada - Mobile Network Experience Report - August 2021. 
https://www.opensignal.com/reports/2021/08/canada/mobile-network-experience 
5G users spent 7.2% to 11.1% of time connected to 5G services. Therefore, these rates reflect the overall experience of 5G users  including when they switch to 3G or 4G.  
To find out what is different about 5G and why it is so concerning, please read  sections 2.3 and 2.4.  
For the rollout schedule for 5G in Canada, see section 2.7.  
  
11 Sperling, Ed. “Millimeter Wave: A Bridge Too Far?” Semiconductor Engineering, February 6, 2020.  https://semiengineering.com/millimeter-wave-a-bridge-too-far/
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2.2. The Electromagnetic Spectrum  
Electromagnetic energy travels in waves and spans a broad spectrum from very long radio  waves to very short gamma rays.12  
Ever since the first radio broadcast, humans have been harnessing the electromagnetic  spectrum for communications.  
Cellular networks send data through radio waves.  
108 Hz = 100 MHz; 109 Hz = 1 GHz; 1010 Hz = 10 GHz; 1011 Hz = 100 GHz  
(from D. Davis, M. Sears, A. Miller, R. Bray. Microwave/Radiofrequency wireless radiation and human health: clinical management in the digital age, Integrative Environmental Medicine, Oxford University Press (2017), pp. 223‐251)13 
The shorter the wave, the higher the frequency. Frequency is measured in Hertz (Hz).   
12 National Aeronautics and Space Administration, Science Mission Directorate. (2010). Anatomy of an  Electromagnetic Wave. Retrieved January 2, 2022, from NASA Science website:  
http://science.nasa.gov/ems/02_anatomy 
13 https://oxfordmedicine.com/view/10.1093/med/9780190490911.001.0001/med‐9780190490911‐chapter‐10
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Radiofrequency (RF) waves occupy the frequency range 3 kHz to 300 GHz.14  
∙ Microwaves are a specific category of radio waves that cover the frequency range 1  GHz to approximately 100 GHz.15 Most microwave ovens use 2.4 GHz, which is also the  frequency used by many Wi-Fi networks.  
∙ Millimetre waves (ultra-short wavelengths, called mmWaves) are a specific category of  radio waves that cover the frequency range 30 to 300 GHz. These are designated as  "Extremely high frequency" or EHF by the International Telecommunication Union.16 (Some wavelengths in the high 20 GHz are also often referred to as mmWaves.)  
Ionizing and Non-ionizing Radiation  
∙ Radiation that carries enough energy to remove an electron from a molecule  causing it to become charged (or ionized) is called ionizing radiation.17 Ionizing  radiation effectively disrupts molecular bonds. In living organisms, such disruption can  cause extensive damage to cells and their genetic material.18 X-rays and gamma-rays  are forms of ionizing radiation.  
∙ Radiation that does not have enough energy to remove an electron is called non ionizing radiation. Radio waves (which include microwaves), infrared radiation, and  visible light are all forms of non-ionizing radiation.  
Radio frequency (RF) waves used in wireless communication are in the non-ionizing range  of the electromagnetic spectrum.  
It was once thought that non-ionizing radiation could not  
damage DNA or cellular tissue.  
We now know that it can – just in different ways. 
Please see section 3.1 and Appendix 4 for peer-reviewed studies  that show harm from non-ionizing radiation. 
RF waves are covered by Health Canada’s Safety Code 6, the code that serves as the  scientific basis for equipment certification and exposure compliance specifications outlined  in ISED's regulatory documents governing the use of wireless devices and antennas in  Canada. For more on Safety Code 6, see chapter 6.  
  
14 Limits of Human Exposure to Radiofrequency Electromagnetic Energy in the Frequency Range from 3 kHz  to 300 GHz, see Introduction, page 1. https://www.canada.ca/en/health-canada/services/publications/health risks-safety/limits-human-exposure-radiofrequency-electromagnetic-energy-range-3-300.html 15 Different sources define different frequency ranges as microwaves. Kumar, Sanjay; Shukla, Saurabh (2014).  Concepts and Applications of Microwave Engineering. PHI Learning Pvt. Ltd. p. 3. ISBN 978-8120349353.  https://en.wikipedia.org/wiki/Microwave#cite_note-Kumar-2 
16 https://www.itu.int/dms_pubrec/itu-r/rec/v/R-REC-V.431-8-201508-I!!PDF-E.pdf 
17 https://chemed.chem.purdue.edu/genchem/topicreview/bp/ch23/radiation.php 
18 https://www.britannica.com/science/ionizing-radiation 
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2.3. What is different about 5G?  
2.3.1. 5G will be the first cellular network to use millimetre waves (mmWaves)  
Before 5G, wireless communication used the frequency bands below 5.2 GHz.  In Canada, cellular networks used frequencies up to 2.6 GHz.  
5G will use those same frequencies (and the recently auctioned 3.5 GHz band) plus  it intends to add high frequency millimetre waves (mmWaves) to the mix.  
Wavelength impacts speed and distance of data transmissions.  
Signals sent using higher frequencies have a higher data-carrying capacity, but lower  propagation distances, and the opposite for signals sent using lower frequencies; these  carry less data but travel much further through the environment.19  
Higher data-carrying capacity translates into faster transmission speeds. It is therefore the  mmWaves (which are not yet available) that will ensure the super fast speeds  promised. 
Solution to a Catch-22: Three Frequency Bands  
To ensure service, 5G networks will operate on three frequency bands, each requiring  different antennas, and each giving a different tradeoff of download speed vs. service  coverage vs. latency.20 A 5G device will connect to the network through the highest speed  antenna within range at its location.21 
According to the GSMA,22 the trade body that represents the interests of mobile network  operators worldwide, these are the three bands that 5G will use:  
∙ Low-band spectrum: Sub-1 GHz (600 MHz in Canada) 
for widespread coverage across urban, suburban, and rural areas and to help  support the Internet of Things (IoT).  
∙ Mid-band spectrum: 1 GHz to 6 GHz (3.5 GHz in Canada)  
is expected to form the basis of many initial 5G services globally.  
∙ High-band spectrum: 6 GHz to 100 GHz (26, 28, 37-40 and 64-71 GHz in Canada)  for the ultra-high broadband speeds. The frequencies to be used in Canada for the  high-band (26 GHz and higher) are sometimes called millimetre waves (mmWaves).  
  
19 Spectrum 101 An Introduction to National Aeronautics and Space Administration Spectrum Management.  2016. page iii. https://www.nasa.gov/sites/default/files/atoms/files/spectrum_101.pdf 20 Network latency is a term used to describe delays in communication over a network. Latency can either be  measured as the Round Trip Time (RTT) or the Time to First Byte (TTFB). According to Verizon, it refers to the  time required for a packet of data to travel round trip between two points. https://www.verizon.com/about/our company/5g/what-network-latency 
21 Horwitz, Jeremy (December 10, 2019). "The definitive guide to 5G low, mid, and high band speeds".  VentureBeat online magazine. https://en.wikipedia.org/wiki/5G 
22 5G Spectrum: GSMA Public Policy Position, March 2020. https://www.gsma.com/spectrum/wp content/uploads/2020/03/5G-Spectrum-Positions.pdf
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Frequency tradeoffs  
Source: From Don Sheppard. 2019. "Radio spectrum in the 5G wireless world", InsightaaS. 
2.3.2. Higher Cell Density: The industry's solution to the short range of mmWaves  
To get around the shorter range of the mmWaves (they also have difficulty passing  through some types of obstacles), millimetre wave 5G antennas will be placed much  closer to homes and in much greater numbers.  
The industry calls it "higher cell density".  
These antennas, called “small cells" or “microcells” (as opposed to the macro cells, i.e. on  tall cell towers), are being placed on lamp posts, hydro poles, on the sides of buildings,  inside malls, conference centres and stadiums, and on other “non-tower” ground level  structures.23 In contrast to current cellular networks requiring one cell tower for every 1-3  km in urban environments, some analyses of 5G networks have concluded that as many as  one “small” cell transmitter will be required for every 2-10 houses, in addition to large cell  towers.  
(From "Update on 5G spectrum in the UK 2017", by Ofcom, the UK regulatory authority for telecommunications, p. 11) 
  
23 Ericsson website. Invisible Sites: Hiding small cells in not-so-plain site.  
https://www.ericsson.com/en/networks/offerings/urban-wireless/invisible-sites 
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2.3.3. The Competition: Low Earth Orbit Satellites to blanket the country  
The Government of Canada is allowing a type of satellite called a non-geostationary satellite  orbit (NGSO) satellite, also known as low earth-orbit satellite or LEO for short, to deliver  high-speed Internet to Canadians.24 These are smaller, brighter, satellites that travel 18  times closer to Earth than traditional telecommunications satellites.  
Elon Musk's SpaceX is planning  
to provide Internet service  
to every inch of the planet  
∙ SpaceX:  
o has already launched  
2,042 satellites  
(Spacenews.com, January 18, 2022),  
o is launching approximately  
60 satellites every two weeks. 
o has the FCC approval to launch  
12,000 low-orbit satellites to create a  
mega-constellation called Starlink  
(Phys.org, 16 November 2018)  
o is trying to get permission to increase  
this to 42,000  
(Tech Times, Oct 16, 2019).  
o has the FCC approval to deploy 1  
million ground antennas for Starlink  
(CNBC, March 20, 2020)  
o obtained CRTC approval in 2020 to  provide low Earth orbit satellite  internet to rural Canadians  
A computer scientist's rendering of SpaceX's constellation of satellites for Starlink. Mark Handley/University College London 
(Canadian Radio-television and Telecommunications Commission).25 
o has begun beta tests with households in Canada – see section 2.7.  
Others planning to offer satellite Internet service to Canadians include:  
∙ Project Kuiper, owned by Amazon's Jeff Bezos, is spending $10 billion US, to  launch 3,200 spacecraft into low earth orbit and offer service within one to two years;  
∙ Telesat – a Canadian company hopes to launch their service in Canada in late 2022  with 298 LEO satellites.26 (Canadian Government investing up to $1.44 billion.)  
Canadian government actively supporting these satellites  
Innovation, Science and Economic Development Canada (ISED) is:  
∙ streamlining its licensing process so satellite systems can be approved faster.27 
∙ funding LEO satellites. In August 2021, ISED entered into an agreement-in-principle  with Telesat to invest $1.44 billion into its satellite constellation "Telesat Lightspeed"  ($790-million repayable loan plus a $650-million equity investment).28   
24 https://www.ic.gc.ca/eic/site/139.nsf/eng/00016.html#leo 
25 https://www.cbc.ca/news/canada/new-brunswick/elon-musk-tesla-starlink-low-earth-orbit-high-speed-rural internet-rockets-satellite-1.5768338 
26 https://www.cbc.ca/news/canada/new-brunswick/broadband-rural-internet-high-speed-access-wireless technology-fibre-optic-cable-1.5748599 
27 https://www.canada.ca/en/innovation-science-economic-development/news/2017/06/improving_high speedinternetaccesstoruralandnortherncommunitiest.html
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2.4. Why is 5G so concerning?  
∙ There has been no research on the health effects of long-term exposure to  mmWave radiation. (We are "flying blind,” to quote a U.S. senator29).  However, we do have considerable evidence about the harmful effects of the  microwaves used in 2G, 3G, 4G and LTE (and therefore some of the lower frequency  bands that will also be used in 5G).  
∙ 5G will not replace 4G; it will accompany it. It will be in addition to current towers.  The plan is to install more towers plus thousands of small cell antennas. 5G networks  will operate on 3 frequency bands each requiring different antennas. Simultaneous  exposure to multiple types of RF radiation will substantially increase our overall risk of  harm. 30 
∙ 5G will require antennas every 100 to 200 metres (according to some sources,  "every few hundred feet"31), exposing people to mmWave radiation in their homes  whether they use it or not.  
∙ 5G will employ new technologies (e.g., active antennas capable of beam-forming;  phased arrays; massive multiple inputs and outputs, known as massive MIMO),  which pose unique challenges for measuring exposures.32 
∙ Citizens are not being consulted. Canada's regulations require public consultations  only for towers (although health concerns are not deemed relevant). Therefore, the  telecom industry can legally install small cell antennas on “non-tower” structures, such  as lamp poles, hydro poles or buildings, in front of people's houses without any  notification. . . and even hide them.  
∙ Tens of thousands of low Earth orbit satellites are being planned to blanket  every inch of the planet with wireless Internet service, forcing every living thing to  be exposed to potentially harmful radiation 24/7.  
∙ Health Canada's exposure guidelines are obsolete. – For details, see chapter 6. 
There will be no place  
for people, wildlife (including pollinators) and trees  
to escape from this harmful environmental pollutant.  
And Canada’s regulations ensure that  
they have no real say in the matter.
 
28 https://www.canada.ca/en/innovation-science-economic-development/news/2021/08/government-of-canada announces-144-billion-investment-in-telesat-supporting-the-future-of-connectivity-for-rural-and-remote communities.html 
29 US Senator Blumenthal Raises Concerns about 5G Wireless Technology Health Risks at Senate Hearing,  Feb 6, 2019. https://www.youtube.com/watch?v=ekNC0J3xx1w&feature=youtu.be 
30 Joel M. Moskowitz (University of California, Berkeley). "We Have No Reason to Believe 5G Is Safe",  Scientific American, October 17, 2019. https://blogs.scientificamerican.com/observations/we-have-no-reason to-believe-5g-is-safe/ 
31 GlobeNewswire. Recent Verizon/Crown Castle Agreement Bodes Well for Digital Locations”, Feb 2, 2021.  https://www.theglobeandmail.com/investing/markets/stocks/CCI/pressreleases/1057872/ 32 Moskowitz, op.cit.  
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2.5. What are the benefits?  
Since the first generation of analog cell phones in the 1980's, wireless communication  networks have evolved rapidly. Today's 4G/LTE networks provide wireless internet access,  email, mobile TV, gaming, movies, navigational maps and more.  
5G promises to provide an entirely new level of connectivity; fast, responsive, with  very wide coverage.  
According to GSMA, the trade body that represents the interests of mobile network  operators worldwide, potential 5G benefits can be grouped into three different classes:  
∙ Enhanced Mobile Broadband (faster wireless Internet access)  Including peak download speeds of at least 20 Gbps and a reliable 100 Mbps user  experience data rate in urban areas. This will better support increased consumption  of video as well as emerging services like virtual and augmented reality.  [According to Cisco, by 2022, 65% of all Internet traffic will be wireless video]. 
∙ Ultra-Reliable and Low Latency Communications 
5G networks are being designed to be more reliable and have very low latencies (network delays)33 to support services such as autonomous vehicles (driverless  cars), and mobile healthcare.  
∙ Massive Machine Type Communications  
Including the ability to support at least one million Internet-of-Things connections per square kilometre with very long battery life and wide coverage including inside  buildings. [According to Cisco, by 2023, machine to machine connections will  account for 50% of all Internet traffic].  
The biggest beneficiaries of 5G will be corporations.  
∙ By facilitating the growth of the Internet-of-Things, 5G will open up new revenue  streams for corporations by providing huge amounts of data (telemetry data, usage  data, consumer behaviour analytics, etc.). Data is the new oil.34 
∙ Also, huge revenues will be generated by the new devices: Qualcomm estimates that  5G will produce up to $12 trillion worth of goods and services.  
Note: Problems around data security and privacy will increase given huge amounts of data will be transferred  over public networks. See sections 3.5 and 3.6 for more on this.  
  
33 Network latency is a term used to describe delays in communication over a network. Latency can either be  measured as the Round Trip Time (RTT) or the Time to First Byte (TTFB). According to Verizon, it refers to the  time required for a packet of data to travel round trip between two points. https://www.verizon.com/about/our company/5g/what-network-latency 
34 The Economist (May 6, 2017). The world’s most valuable resource is no longer oil, but data.  https://www.economist.com/leaders/2017/05/06/the-worlds-most-valuable-resource-is-no-longer-oil-but-data Forbes (Nov 15, 2019). Data Is The New Oil -- And That's A Good Thing.  
https://www.forbes.com/sites/forbestechcouncil/2019/11/15/data-is-the-new-oil-and-thats-a-good thing/#9c53bf473045
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2.6. The Internet of Things (IoT)  
IoT is the generic term used to describe electronic appliances and devices that wirelessly  connect to the internet and to each other. Devices are embedded with sensors, software,  network connectivity and electronics that enable them to collect and exchange data. For  
example: your smart refrigerator can alert you when you run low of certain foods; your  washing machine can connect directly with the manufacturer for a diagnostic; you can adjust  the heat in your house from an app on your mobile phone while you are away.  
IoT is already happening on existing networks.  
IoT applications presently in use: smart appliances (washer/dryers, ovens, refrigerators),  heating, air-conditioning, security systems, wearables (watches, fitness trackers), traffic  sensors, connected cars.  
With 5G, IoT will no longer be constrained by network resources.  The potential applications: driverless cars, health monitoring of patients, optimisation of  street lighting to suit the weather or traffic; environmental monitoring, "smart" agriculture,  and "smart" manufacturing. – Section 3.3.5 has information on the Internet of Underwater Things ( IoUT). 
A significant number of these applications can be implemented  
with a safer, cheaper, greener, and more secure wired solution. (see section 9.1) Unfortunately, little research and development is being invested  
to find these solutions. 
2.7. When will 5G be rolled out in Canada?  
5G rollout has begun all across Canada.  
“The Big Three” telecommunications giants in Canada who control 90% of the market are  Rogers Communications (Rogers Wireless), BCE (Bell Mobility) and Telus (Telus Mobility).  They have all begun offering a version of 5G, using the low- and/or mid-band frequencies  (below 6 GHz).35,36 
In order to offer the full 5G, they are waiting for the Canadian government (Ministry of  Innovation, Science and Economic Development) to auction the high-band, i.e., the  extremely high frequency millimetre waves (mmWaves). The auction of the high frequency  bands has been delayed until the first quarter of 2024.37  
Small cell antennas are already being deployed close to homes.  
The low- and mid-band frequencies that are being used for the 5G currently being rolled out  can travel great distances and can easily penetrate buildings; therefore, they can be  transmitted effectively from the large towers. This is why the telecommunications industry  has been ramping up its deployment of more and more cell towers during the pandemic.  
In addition, in preparation for the high-band frequencies (mmWaves) which cannot travel far  nor through obstacles as easily, the telecom industry has been installing thousands of  antennas close to homes, and using them to broadcast the mid-range band.    
35 Rogers https://about.rogers.com/news-ideas/canadas-first-and-largest-5g-network-expands-to-over-50-new cities-and-towns/ 
36 Bell https://www.whistleout.ca/CellPhones/Guides/bell-5g 
37 ISED. Decision on the Technical and Policy Framework for the 3650-4200 MHz Band and Changes to the  Frequency Allocation of the 3500-3650 MHz Band. Item 345. https://www.ic.gc.ca/eic/site/smt gst.nsf/eng/sf11699.html 
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5G Spectrum Auctions – Estimated Schedule  

Band 
Auction scheduled for 

Low-band spectrum  
(sub-1GHz)  
for outdoor to indoor penetration
600 MHz 
completed Spring 2019  
(raised $ 3.5 billion)38

Mid-band spectrum  
(1 to 6 GHz)  
for balance between coverage  and carrying capacity 
3,500 MHz (3.5 GHz)  
3,800 MHz (3.8 GHz) 
completed June 202139 
Early 2023 

High-band spectrum 
(24 to 100 GHz)  
for increased data rate 
26 GHz  
28 GHz  
37-40 GHz  
64-71 GHz 
Early 2024 (first quarter) 

32 GHz (for backhaul)  70 GHz (for backhaul)  80 GHz (for backhaul) 
unknown 


  
Sources: ISED’s Spectrum Outlook 2018 to 2022 and “Decision on the Technical and Policy Framework  for the 3650-4200 MHz Band and Changes to the Frequency Allocation of the 3500-3650 MHz Band”,  May 2021, paragraph 345, https://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf11699.html 
Wireless Internet soon to be deployed over our heads . . . without the consent of  Canadians: Go-ahead given to SpaceX to blanket Canada with satellites  
Companies planning to offer satellite Internet service to Canadians include:  
∙ Elon Musk's SpaceX has begun beta tests on the service with households in Canada,  and is currently operating in 14 countries, with license applications pending in others.40 SpaceX has the FCC approval to launch 12,000 low-orbit satellites to provide  wireless Internet service to every inch of the planet. This mega-constellation of  satellites, called Starlink, will orbit 18 times closer to the Earth compared to traditional  telecommunications satellites. Its application to provide low Earth orbit satellite internet  to rural Canadians was approved in 2020 by the Canadian Radio-television and  Telecommunications Commission (CRTC).41 
∙ Project Kuiper, owned by Amazon's Jeff Bezos, plans to launch 3,200 spacecraft  into low earth orbit and offer service within one to two years;  
∙ Telesat, a Canadian company, hopes to launch its service in late 202242 with the help  of the Canadian Government (agreement-in-principle to invest $1.44 billion).  
For more information on these satellites, see section 2.3.3.  
  
38 https://www.reuters.com/business/media-telecom/canada-launches-long-awaited-auction-5g-spectrum 2021-06-15/ 
39 ISED. 3500 MHz auction – Process and results. July 29, 2021 https://www.canada.ca/en/innovation science-economic-development/news/2021/07/3500-mhz-auction--process-and-results.html 40 https://www.businessinsider.com/spacex-starlink-dish-terminal-elon-musk-satellite-internet-2021-8 41 https://www.cbc.ca/news/canada/new-brunswick/elon-musk-tesla-starlink-low-earth-orbit-high-speed-rural internet-rockets-satellite-1.5768338 
42 https://www.cbc.ca/news/canada/new-brunswick/broadband-rural-internet-high-speed-access-wireless technology-fibre-optic-cable-1.5748599
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3. Why are we concerned?  
“In my lifetime our exposure to radiofrequency radiation  
has increased by up to a billion billion times.  
There is no excuse any more for pretending this is not harmful  
– to us and to all life on the planet.  
Radiofrequency radiation is the new tobacco.  
Anybody sincerely reading the science  
should be deeply, deeply concerned.”  
– Dr. Damien Downing, President,  
The British Society for Ecological Medicine  
3.1. Health Effects (Long-term)  
 “Human beings are bioelectrical systems.  
Our hearts and brains are regulated by internal bioelectrical signals.  
Environmental exposures to artificial EMFs can interact with  
fundamental biological processes in the human body.  
We have good evidence these exposures can damage our health,  
or that of children of the future who will be born  
to parents now immersed in wireless exposures.”  
– The BioInitiative Report 2012  
3.1.1. There has been no research on the health effects of long-term exposure  to 5G.  
Current wireless devices and antennas that use 2G, 3G, 4G and LTE, have serious health  consequences associated with them which also apply to 5G which will use many of those  same frequencies.  
However, in addition to those frequencies, 5G will add millimetre waves to the mix, PLUS it  will employ new technologies (see sections 2.1 and 2.4). There has been no research on  the health effects of long-term exposure to radiation from 5G technologies. Furthermore, we know that no such studies are being planned in the USA43 and are not  aware of any planned for Canada. 
3.1.2. Thousands of peer-reviewed studies show serious adverse health effects  of current wireless technologies.  
The jury is no longer out. There is now more than enough evidence to warrant a  precautionary approach which includes putting a stop to wireless 5G.  
Hundreds of high-quality peer-reviewed studies have shown that RF radiation affects  living organisms at levels well below most international and national guidelines, including  Canada's. 44,45,46,47,48,49,50.  
  
43 Senate Commerce, Science, and Transportation Committee hearing of the future of 5G wireless technology.  February 17, 2019. https://www.blumenthal.senate.gov/newsroom/press/release/at-senate-commerce-hearing blumenthal-raises-concerns-on-5g-wireless-technologys-potential-health-risks 
44 National Toxicology Program. Cell Phone Radio Frequency Radiation  
https://ntp.niehs.nih.gov/results/areas/cellphones/index.html 
45 Falcioni, L., et al. (2018). Report of final results regarding brain and heart tumors in Sprague-Dawley rats  exposed from prenatal life until natural death to mobile phone radiofrequency field representative of a 1.8 GHz 
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Proven effects of RF radiation:  
∙ increased cancer risk  
∙ sperm damage  
∙ DNA damage  
∙ neurological disorders  
∙ learning and memory deficits (childhood development)  
∙ cellular stress  
∙ oxydative stress  
∙ increase in harmful free radicals 
It would be easy to inundate you with credible studies. Instead we will mention the  following and direct you to a few websites if you would like to see more.  
∙ The BioInitiative 2012 Report,51 prepared by 29 authors from ten countries,  reviewed over 1,800 studies published in the five preceding years that reported  adverse effects at exposure levels ten to hundreds and, some, thousands of times lower  than allowed under safety limits in most countries, including Canada.  
Major areas of concern: damage to DNA and genes; carcinogenicity; reduction in  free-radical scavengers – particularly melatonin; neurotoxicity in humans and  animals; serious impacts on human and animal sperm morphology and function;  effects on memory, learning, attention, behaviour, sleep disruption.  
∙ In 2018, echoing those concerns, a Lancet Planetary Health52 article reported that, of  2,266 studies evaluated, 1,546 “demonstrated significant biological or health effects  associated with exposure” – both acute and chronic – to anthropogenic EMR, including  RFR. According to the authors, these findings deserve “urgent attention”.  
They pointed to evidence that:  
o The damage goes beyond thermal effects and can alter human brain metabolism,  electrical activity in the brain and immune responses;  
o Chronic exposure has been associated with increased oxidative stress, DNA  damage and cancer risk;  
o There is an association between neurodevelopmental or behavioural disorders in  children and their exposure to wireless devices;  
o Prenatal exposure can cause structural and functional changes in the brain  associated with ADHD-like behaviour.  
 
GSM base station environmental emission. Environmental Research.  
https://doi.org/10.1016/j.envres.2018.01.037 
46 Pall, M. L. (2015). Scientific evidence contradicts findings and assumptions of Canadian Safety Panel 6:  microwaves act through voltage-gated calcium channel activation to induce biological impacts at non-thermal  levels, supporting a paradigm shift for microwave/lower frequency electromagnetic field action. Reviews on  Environmental Health, 30(2), 99–116. https://doi.org/10.1515/reveh-2015-0001 
47 Canadian scientists urge more research into safety of wireless technology, saying recent report downgrades  cancer risk. The National Post. April 15, 2014. https://nationalpost.com/health/canadian-scientists-urge-more research-into-safety-of-wireless-technology-saying-recent-report-downgrades-cancer-risk 48 https://www.powerwatch.org.uk/science/studies.asp 
49 https://bioinitiative.org/conclusions/ 
50 https://www.saferemr.com/2014/08/why-we-need-stronger-cell-phone_43.html 
51 https://bioinitiative.org/ 
52 Bandara, P. and David O. Carpenter. (2018). Planetary electromagnetic pollution: it is time to assess its  impact. https://www.thelancet.com/journals/lanplh/article/PIIS2542-5196(18)30221-3/fulltext#articleInformation 
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∙ The $30 million large-scale animal study by the US National Toxicology program (NTP), National Institutes of Health (2018) found “clear evidence” of cancer.53  
∙ The Italian Ramazzini Institute duplicated the NTP findings54 of cancer from  exposure to radiofrequency radiation at cell tower emission levels (2018).  
∙ Miller at al. (2018)55 present the science that would justify upgrading RF radiation to a  Group 1 “known carcinogen” classification by the WHO’s International Agency for  Research on Cancer. Asbestos and cigarette smoke are in Group 1. See 3.1.3 for details.  
∙ The Switzerland BERENIS report56 has identified the likely mechanism of damage from  radiofrequency non-ionizing radiation (at one time it was thought that the energies from  non-ionizing radiation could not damage DNA).  
2020 CONSENSUS STATEMENT  
of UK and International Medical and Scientific Experts and Practitioners  on Health Effects of Non-Ionising Radiation (NIR)  
Signed by groups representing more than 3,500 medical doctors  
This is an important statement that should be read by all concerned about public health.  
https://phiremedical.org/wp-content/uploads/2020/11/Press-Release-2020-Non-Ionising-Radiation Consensus-Statement-1.pdf
For more information on the 2020 Consensus Statement,57 see section 4.3.  
For more peer-reviewed studies, see Appendix 4 and visit these websites: Physicians for Safe Technology https://mdsafetech.org/  
Canadians for Safe Technology http://c4st.com/ 
Environmental Health Trust https://ehtrust.org/science/top-experimental epidemiological-studies/ 
EMR Safety https://www.saferemr.com  
TechSafeSchools http://techsafeschools.com/ 
  
53 National Toxicology Program. Cell Phone Radio Frequency Radiation  
https://ntp.niehs.nih.gov/results/areas/cellphones/index.html 
54 Falcioni, L., et al. (2018). Report of final results regarding brain and heart tumors in Sprague-Dawley rats  exposed from prenatal life until natural death to mobile phone radiofrequency field representative of a 1.8 GHz  GSM base station environmental emission. Environmental Research.  
https://doi.org/10.1016/j.envres.2018.01.037 
https://www.sciencedirect.com/science/article/pii/S0013935118300367?via%3Dihub 55 Miller, A. B. et al. (2018). Cancer epidemiology update, following the 2011 IARC evaluation of  radiofrequency electromagnetic fields (Monograph 102). Environmental Research, 167, 673–683.  https://doi.org/10.1016/j.envres.2018.06.043 
56 Federal Office for the Environment (FOEN). (2020). BERENIS - Swiss expert group on electromagnetic  fields and non-ionising radiation. Retrieved January 27, 2021, from  
https://www.bafu.admin.ch/bafu/en/home/themen/thema-elektrosmog/newsletter-beratende-expertengruppe nis--berenis-/beratende-expertengruppe-nis-berenis.html 
57 2020 Consensus Statement of UK and International Medical and Scientific Experts and Practitioners on  Health Effects of Non-Ionising Radiation (NIR) 
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3.1.3. A Known Human Carcinogen  
Cancer remains the leading cause of death in Canada.  
Nearly 1 in 2 Canadians will develop cancer in their lifetime. 1 in 4 will die from cancer.  An estimated 1,000 children (aged 0-14 years) are diagnosed each year.  -- According to the report “Projected estimates of cancer in Canada in 2020” 58 
In 2011, the World Health Organization's International Agency for Research on Cancer  (IARC) classified RF radiation (RFR) as "possibly carcinogenic" (Group 2B – the same  category as lead and DDT at the time).  
Since then, there has been even more epidemiological evidence as well as animal studies  that confirm ‘clear evidence’ of carcinogenicity – including the two largest investigations ever  undertaken globally, from the widely respected National Toxicology Program (USA) and the  Ramazzini Institute (Italy). Experts now state unequivocally that RF radiation should  urgently be re-classified as a "known human carcinogen". 59,60 
Dr. Anthony B. Miller is one of them. A highly respected expert in the field and one of the  reviewers for IARC’s monograph (volume 102, 2013) that supported the designation of RF  radiation as a Group 2B human carcinogen, he has since stated publicly:  
“The evidence indicating wireless is carcinogenic  
has increased and can no longer be ignored.”  
-- Dr. Anthony B. Miller, July 31, 2017 lecture in Jackson Hole, Wyoming  
He now believes the evidence published since 2011 fulfills the requirements to classify RF  radiation as "carcinogenic to humans" (Group 1) as are asbestos and cigarette smoking  . . . and he should know. See his biography on next page.  
Here are the highlights of what he and his co-authors found in their 2018 review of  epidemiology studies published since the IARC 2011 categorization of RFR61:  
∙ Increased risk of brain, vestibular nerve and salivary gland tumors are associated with  mobile phone use.  
∙ Nine studies (2011–2017) report increased risk of brain cancer from mobile phone use.  ∙ Four case-control studies report increased risk of vestibular nerve tumors.  ∙ Concern for other cancers: breast (male & female), testis, leukemia, and thyroid.  
“When considered with recent animal experimental evidence, the recent epidemiological  studies strengthen and support the conclusion that RFR should be categorized as  carcinogenic to humans (IARC Group 1).”– excerpt from the abstract of his 2018 review 
  
58 Brenner, Darren R., Hannah K. Weir, et al. Projected estimates of cancer in Canada in 2020. CMAJ Mar  2020, 192 (9) E199-E205; DOI: 10.1503/cmaj.191292 https://www.cmaj.ca/content/192/9/E199 59 Miller, A. B. et al. (2018). Cancer epidemiology update, following the 2011 IARC evaluation of  radiofrequency electromagnetic fields (Monograph 102). Environmental Research, 167, 673–683.  https://doi.org/10.1016/j.envres.2018.06.043 
60 Hardell, L., & Carlberg, M. (2018). Comments on the US National Toxicology Program technical  reports on toxicology and carcinogenesis study in rats exposed to whole-body radiofrequency  radiation at 900 MHz and in mice exposed to whole-body radiofrequency radiation at 1,900 MHz.  International Journal of Oncology. https://doi.org/10.3892/ijo.2018.4606 
61 Miller, A. B. et al. (2018). Cancer epidemiology update, following the 2011 IARC evaluation of  radiofrequency electromagnetic fields (Monograph 102). Environmental Research, 167, 673–683.  https://doi.org/10.1016/j.envres.2018.06.043
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“Based on the evidence reviewed it is our opinion that IARC's current categorization  of RFR as a possible human carcinogen (Group 2B)  
should be upgraded to Carcinogenic to Humans (Group 1).”  
Other experts agree.  
Researchers Lennart Hardell and Michael Carlberg have published several epidemiological  studies that found increased brain cancer associated with long-term cell phone use and  conclude that “RF radiation should be regarded as a human carcinogen causing glioma.”  In addition, published epidemiological research has also found persons diagnosed with  brain cancer had decreased survival rates associated with higher wireless phone use.  
In 2019, the WHO's International Agency for Research on Cancer (IARC) put RFR  on a priority list for re-evaluation of the classification.  
Their rationale is that there is "new bioassay and mechanistic evidence".62 
"based on new evidence, non-ionizing radiation (radiofrequency)  
should be a high priority for re-evaluation of the classification" 
– Report of the Advisory Group to Recommend Priorities  
for the IARC Monographs during 2020–202463 
Dr. Anthony B. Miller 
∙ Physician epidemiologist specializing in cancer etiology, prevention and screening  ∙ Professor Emeritus, Dalla Lana School of Public Health, University of Toronto  ∙ Longtime advisor to the World Health Organization (WHO)  
∙ Awarded the Medal of Honour by the WHO’s International Agency for Research  on Cancer (IARC)  
∙ Member of the Order of Canada (2019)  
In the course of his illustrious career, he has served as:  
∙ Senior Epidemiologist, International Agency for Research on Cancer;  
∙ Director, Epidemiology Unit, National Cancer Institute of Canada;  
∙ Chair, Department of Preventive Medicine and Biostatistics, University of Toronto;  ∙ Head, Division of Cancer Epidemiology, German Cancer Research Centre;  ∙ Consultant, Division of Cancer Prevention, U.S. National Cancer Institute.  
Dr. Miller has conducted research on electromagnetic fields and cancer, and has  served on many committees assessing carcinogenicity of various exposures.  He was visiting Senior Scientist in the IARC Monographs programme as a reviewer to  the scientific literature supporting designation of Radiofrequency Electromagnetic  Fields as a Group 2B possible human carcinogen in 2011.  
He was invited to speak to the House of Commons Standing Committee on Health for  their report entitled “Radiofrequency Electromagnetic Radiation and the Health of  Canadians” (For more on this Report, see Section 6.3) 
  
62 "Advisory Group recommendations on priorities for the IARC Monographs" in The Lancet Oncology,  Elsevier, June 2019. https://www.thelancet.com/journals/lanonc/article/PIIS1470-2045(19)30246-3/fulltext 63 https://monographs.iarc.fr/wp-content/uploads/2019/10/IARCMonographs-AGReport-Priorities_2020- 2024.pdf 
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3.1.4. Children and Other Vulnerable Populations  
Everyone is at risk for long-term harm from exposure to wireless radiation – even if they  cannot feel it. However, the most vulnerable are children, pregnant women, the elderly and  those who are ill, in particular the immune compromised.  
People who are sensitive to RF radiation, feel immediate effects. These are considered “the  canaries in the mine” and the effects that they experience are outlined in section 3.2.  
Children are not “Little Adults”. They are more susceptible to the harmful effects of RF  radiation (RFR) from their early development in the womb until after adolescence.  
The following is extracted from: Clegg, F. M., Sears, M., Friesen, M., Scarato, T., Metzinger, R., Russell, C.,  Stadtner, A., & Miller, A. B. (June 2020). Building science and radiofrequency radiation: What makes smart and  healthy buildings, Building and Environment, 176(106324), https://doi.org/10.1016/j.buildenv.2019.106324.  
During their rapid development, the embryo, fetus, infant and child are more  vulnerable to many environmental insults, and impacts are potentially lifelong. Various life stages have different vulnerabilities and susceptibilities to RFR.64,65,66,67 Modeling indicates that children absorb substantially higher RFR doses from cell  phones, in deeper brain structures, than do adults (Fig. 2).68 Research has also  found proportionately higher doses to tissues in children compared with adults, from  wireless laptops and utility meters. 
Fig. 2. Specific Absorption Rate (SAR) in adult and child (age 6 years) male heads with phone in talk position.  The scale is 50 dB with 0 dB = 1.6 mW/kg. From work of Claudio Férnandez, 201869 (used with permission of  Environmental Health Trust).  
  
64 https://www.degruyter.com/view/j/reveh.2015.30.issue-4/reveh-2015-0030/reveh-2015-0030.xml 65 https://www.ncbi.nlm.nih.gov/pubmed/21999884 
66 https://www.tandfonline.com/doi/full/10.3109/15368378.2011.622827 
67 https://iopscience.iop.org/article/10.1088/0031-9155/55/7/001 
68 https://www.sciencedirect.com/science/article/abs/pii/S0013935118302561?via%3Dihub 69 https://www.sciencedirect.com/science/article/abs/pii/S0013935118302561?via%3Dihub
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Research has linked exposure during pregnancy to adverse effects.  The authors of a case-control study published in 2015 stated, “use of mobile phones  can be related to early spontaneous abortions”.70 Maternal mobile phone use during  the first trimester of pregnancy may contribute to slowing or halting of embryonic  development,71 possibly due to effects on membrane receptors in human amniotic  cells.72 A 2019 study of over 55,000 pregnant women and infants in four countries  (Denmark, the Netherlands, Spain and Korea) linked maternal cell phone use during  pregnancy with shorter pregnancy duration and increased risk for preterm birth.73  
Behavioral problems have been associated with prenatal and postnatal cell  phone exposure.  
In five cohorts, Birks et al. found cell phone use by a pregnant woman to be  associated with an increased risk for behavioral problems, particularly  hyperactivity/inattention in her child,74 and Divan et al. reported behavioral problems  in children up to seven years of age.75,76 Studies of children and adolescents report  possible associations of wireless technology use with addictions and depression,77 fatigue,78 altered baseline thyroid hormone levels,79 and poorer well-being.80,81  Sage and Burgio discuss the damage from low levels of RFR to genetic material  including DNA and nuclear structures in the cell, and potential mechanisms of child  neurodevelopmental impairment.82  
A Yale University study found that when mice were exposed in utero to cell phone  radiation, they had impaired memory and increased hyperactivity in adulthood.83 
Not only can RF radiation act along with carcinogens to promote tumor  development,84 it also may synergize with toxic chemicals in other ways.  For example, in a study of Attention Deficit Hyperactivity Disorder in children, ADHD  was associated with mobile phone use for voice calls only in children who were also  exposed to relatively high lead levels (lead is an established, potent neurotoxin).85  
End of excerpt  
  
70 https://link.springer.com/article/10.1186%2Fs40201-015-0193-z 
71 https://www.ncbi.nlm.nih.gov/pubmed/20568468 
72 https://www.tandfonline.com/doi/full/10.3109/09553002.2011.634882 
73 https://academic.oup.com/aje/article/188/7/1270/5474947 
74 https://www.sciencedirect.com/science/article/pii/S0160412016307383?via%3Dihub 75https://journals.lww.com/epidem/Fulltext/2008/07000/Prenatal_and_Postnatal_Exposure_to_Cell_Phone_Us e.1.aspx 
76 https://jech.bmj.com/content/66/6/524 
77 https://www.sciencedirect.com/science/article/pii/S0747563215303320 
78 https://bmjopen.bmj.com/content/5/5/e007302 
79 https://www.sciencedirect.com/science/article/pii/S0048969715303946?via%3Dihub 80 https://ehjournal.biomedcentral.com/articles/10.1186/1476-069X-12-90 
81 https://ehjournal.biomedcentral.com/articles/10.1186/s12940-016-0116-1 
82 https://srcd.onlinelibrary.wiley.com/doi/abs/10.1111/cdev.12824 
83 https://www.nature.com/articles/srep00312 
84 https://www.sciencedirect.com/science/article/abs/pii/S0006291X15003988?via%3Dihub 85 https://journals.plos.org/plosone/article?id=10.1371/journal.pone.0059742
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3.1.5. Canadians are already overexposed to microwave radiation  
Children are overexposed in schools and in their homes. Cancer patients are exposed in  hospitals. It is impossible to buy a new car – or for that matter a washing machine – that  does not expose you to RF radiation. It is impossible to travel without being exposed to  microwaves – from Wi-Fi on trains, buses, planes and in hotels, to the Wi-Fi and Bluetooth  in your car and the cell towers radiating along the highways. It is difficult to find a restaurant  that does not have Wi-Fi . . . not to mention all the people with "smart" devices all around you.  
 “I have no doubt in my mind that at the present time,  
the greatest polluting element in the earth’s environment  
is the proliferation of electromagnetic fields.  
I consider that to be far greater on a global scale, than warming,  
and the increase in chemical elements in the environment.”86 
Dr. Robert O. Becker  
Twice nominated for a Nobel prize in medicine  
State University of New York (deceased) 
3.2. Health Effects (More Immediate):  
Electromagnetic Hypersensitivity – The Canaries in the Coal Mine  
The following is extracted from: Clegg, F. M., Sears, M., Friesen, M., Scarato, T., Metzinger, R., Russell, C.,  Stadtner, A., & Miller, A. B. (June 2020). Building science and radiofrequency radiation: What makes smart and  healthy buildings, Building and Environment, 176(106324), https://doi.org/10.1016/j.buildenv.2019.106324.  
As with other environmental exposures, some people are more susceptible  (sensitive or intolerant) and overtly affected by wireless technologies. Electromagnetic hypersensitivity (EHS) is also commonly termed electrical sensitivity,  electrohypersensitivity, idiopathic environmental intolerance, or (historically)  microwave sickness.  
Common symptoms of EHS include87,88:  
∙ headaches  
∙ cognitive difficulties  
∙ sleep problems  
∙ dizziness  
∙ depression  
∙ fatigue  
∙ skin rashes  
∙ tinnitus  
∙ flu-like symptoms  
Adverse reactions to wireless devices range from mild and readily reversible to  severe and disabling, and individuals must greatly reduce their exposures to sources  of electromagnetic radiation.89,90,91  
  
86 https://www.hindawi.com/journals/ab/2014/198609/ 
87 https://www.ncbi.nlm.nih.gov/pubmed/22153604 
88 https://www.ncbi.nlm.nih.gov/pubmed/7881769 
89 https://www.researchgate.net/publication/283718065_The_microwave_syndrome_or_electro hypersensitivity_historical_background 
90 https://www.ncbi.nlm.nih.gov/pubmed/26372109 
91 https://www.chrc-ccdp.gc.ca/eng/content/medical-perspective-environmental-sensitivities
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Surveys conducted in several countries at times ranging from 1998 to 2007 estimated  that approximately three to thirteen percent or more of the population  experience symptoms of EHS.92,93,94,95 
As well as being difficult to manage in the modern world, EHS is typically  unexpected. The theory that EHS is merely a “nocebo” response – that it results from  suggestion and worry over possible effects of electronic devices – is the opposite of  experience. In a study of 40 people, their EHS was only recognized following a  period of illness and self-experimentation.96  
Further research has confirmed that lived experience is not consistent with the  nocebo hypothesis.97  
EHS is recognized as a disability and is accommodated in the U.S. under the  Americans With Disabilities Act.98 Sweden recognizes EHS as a functional  impairment.99 In Canada, the condition is included under environmental  sensitivities100,101 by the Canadian Human Rights Commission. Internationally there  are several lawsuits related to cell phones and cancer and disability from EMF  exposures. For example, Australian102 and Spanish103 courts have awarded disability  to workers claiming sensitivity to electromagnetic radiation.  
Physicians’ organizations’ research, experiences, practices and statements over the  years were summarized by the European Academy of Environmental Medicine  (EUROPAEM) in 2016.104 Sensitivities vary among individuals, and symptoms may  also occur with exposures outside the RFR range.  
The consensus of the EUROPAEM EMF Guideline is that the most important  action for treatment and management of EHS is reduction and avoidance of  pertinent exposures in locations where significant amounts of time are spent,  especially in sleeping areas.  
Other recommended measures include a suite of healthy lifestyle measures such as  nutrition, stress reduction and measures to avoid toxicants, as well as to reduce  levels of toxicants sequestered in the body.105 
End of excerpt  
The Canadian Guide for Indoor Air Quality states that people with chemical sensitivities may be  more sensitive to other factors in their environment such as radiation from wireless communications  and electrical equipment.106 
  
92 https://www.ncbi.nlm.nih.gov/pubmed 
93 https://iopscience.iop.org/article/10.1088/1755-1315/10/1/012005/meta 
94 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC1241215/ 
95 https://www.ncbi.nlm.nih.gov/pubmed/21982467 
96 https://www.ncbi.nlm.nih.gov/pubmed/26369906 
97 https://www.ncbi.nlm.nih.gov/pubmed/30920673 
98 https://www.access-board.gov/research/completed-research/indoor-environmental quality/recommendations-for-accommodations 
99 https://iopscience.iop.org/article/10.1088/1755-1315/10/1/012005/meta 
100 https://www.chrc-ccdp.gc.ca/sites/default/files/envsensitivity_en.pdf 
101 https://www.chrc-ccdp.gc.ca/eng/content/policy-environmental-sensitivities 
102 http://www7.austlii.edu.au/cgi-bin/viewdoc/au/cases/cth/aat/2013/105.html 
103 http://cemical.diba.cat/sentencies/fitxersSTSJ/STSJ_327_2016.pdf 
104 https://www.ncbi.nlm.nih.gov/pubmed/27454111 
105 https://www.ncbi.nlm.nih.gov/pubmed/27454111
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3.3. Impacts on Wildlife, Including Birds and Pollinators, and Plants  
“Where healthy, breeding bird populations had persisted,  
once cell towers were installed and operating,  
nest and site abandonment, plumage deterioration, locomotion problems,  reduced survivorship, and death were noted in House Sparrows,  
White Storks, Rock Doves, Magpies, Collared Doves, and other species.  This was documentation in the field of some very troubling consequences  of the impacts of cell tower radiation on wildlife”.107 
-- Albert Manville, PhD, retired Senior Wildlife Biologist,  
US Fish and Wildlife Service  
Damage goes well beyond the human race.  
There is growing evidence of harmful effects to both plant and animal life.  
The dramatic worldwide decline of populations of birds, insects and other species makes  this an urgent issue. According to scientists who specialize in this field, exposure to wireless  radiation at ambient levels may well be a co-factor, along with pesticides, habitat loss and  climate change.  
Electromagnetic interactions are intrinsic in living tissues.  
"Brain waves are electrical, the heartbeat is electrical, the cell membrane has an  electric field potential, cell division is electrically influenced, communication between  neurons is electrical, and all of the hormonal and enzymatic activities are electrically  regulated. Even the chemical-mechanistic model of the human and animal anatomy  is essentially an electromagnetic model, because all chemical reactions involve the  sharing, trading, or exchange of electrons at the elemental level".-- Albert Manville, PhD  
Life on Earth has developed in an environment of fairly static geomagnetic fields and  weak natural electromagnetic fields. The cells of all life forms normally communicate  within and among themselves with exquisitely low-intensity electromagnetic and chemical  signaling. Over recent decades, man-made electromagnetic fields have significantly  altered this natural background. Ambient levels of EMR in some areas have increased up  to a quintillion times the natural background levels (a quintillion is 1 with 18 zeros).  
Retired senior wildlife biologist and former lead on telecommunications impacts at the US  Fish and Wildlife Service, Dr. Albert Manville has investigated the impacts of radiation on  migratory birds and other wildlife since the late 1990s, and has published numerous studies  showing harm and testified about the impacts of cell towers on birds. He has stated that108:  
“The race to implement 5G and the push (…) to approve  
the related 5G license frequencies to industry  
are very troubling and downright dangerous.”  
-- Albert Manville, PhD, Retired Senior Wildlife Biologist and  
Former Lead on Telecommunications Impacts, US Fish and Wildlife Service 
 
106 Canadian Committee on Indoor Air Quality (CCIAQ). Guide for Indoor Air Quality, Modules 13 and 14.  https://iaqresource.ca/iaq-guides/ 
107 Statement From Dr. Albert Manville On The FDA Report On Cell Phone Radiation. Environmental Health  Trust. https://ehtrust.org/press-statement-from-dr-albert-manville-on-the-fda-report-on-cell-phone-radiation-2/ 
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3.3.1. What we know: The growing evidence  
RF radiation may be contributing to bird  
population declines, bee colony collapse  disorder and the dramatic drop in insect  
numbers reported recently.  
There is a growing body of peer-reviewed  
studies reporting that RF radiation can cause:  
∙ harm to the navigational ability of  
birds and bees  
∙ nest and site abandonment, reduced  
survivorship and death in nesting birds  
∙ damaged leaves and foliage die-off in  
trees  
A 2013 review of 113 plant and animal  
studies catalogs those findings and more on  the impacts of RFR.109 Dr. Cindy Russell  
published an eye-opening article entitled  
“Wireless Silent Spring”110 in 2018 which  
draws parallels between toxic chemicals and RF radiation.  
Photo Dreamstime
For a list of some of the key studies showing harm to non-human life, see Appendix 5.  
The following is modified from Clegg et al. 2019111:  
Biological systems are integrated, complex and operate using minute electrical  charges combined with precise chemical signals. These mediate complex  functions such as development, reproduction and cognition.  
Recent research has demonstrated adverse effects of radiofrequency radiation (RFR)  on environments and wildlife, including birds, amphibians, insects, fish, mammals  and plants.112,113,114 For example, trees near cell towers can become visibly  unhealthy on the side facing a cellular antenna, and can die.115  
A diverse array of species depends upon the Earth’s low-level magnetic field to  navigate for migration, homing, breeding, foraging and survival. RFR can have  significant long-term impacts on the natural environment via disruption of normal  positioning and orientation abilities as well as other complex cellular and biologic  processes. Incremental effects may be only slowly recognized as species and  ecosystems decline.  
 
108 Albert Manville. Briefing Comment to the FCC. June 3, 2020. 
https://www.fcc.gov/ecfs/filing/1060315601199 
109 Cucurachi, S., Tamis, W. L., Vijver, M. G., Peijnenburg, W. J., Bolte, J. F., & de Snoo, G. R. (2013). A  review of the ecological effects of radiofrequency electromagnetic fields (RF-EMF). Environment  international, 51, 116–140. https://doi.org/10.1016/j.envint.2012.10.009  
https://pubmed.ncbi.nlm.nih.gov/23261519/ 
110 Russell, Cindy. Wireless Silent Spring. Article published in the October 2018 issue of the Santa Clara  County Medical Association Bulletin. https://mdsafetech.files.wordpress.com/2018/11/wireless-silentspring_- sccma-oct-2-2018.pdf 
111 Clegg et al. 2020. https://doi.org/10.1016/j.buildenv.2019.106324 
112 Cucurachi et al. 2012. https://www.ncbi.nlm.nih.gov/pubmed/23261519 
113 Fernie et al. 2000. https://www.ncbi.nlm.nih.gov/pubmed/10685907 
114 Balmori and Hallberg 2007. https://www.tandfonline.com/doi/abs/10.1080/15368370701410558 115 Waldmann-Selsam et al. 2016. https://www.ncbi.nlm.nih.gov/pubmed/27552133 
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Birds, Bees, Magnetoreception and Migration  
Small deposits of the iron-containing mineral magnetite act as magnetoreceptors in a  variety of organisms, including bacteria, insects, fish, birds and mammals116,117,118  which are used to sense the Earth’s magnetic field. Some bird species are strongly  influenced by the low intensity magnetic fields of the Earth for directional reference.  Newer studies suggest that light-dependent cryptochrome photo receptors in birds’  eyes are also sensitive to magnetic forces, and communicate with the brain.119,120  
RFR can interfere directly with magnetoreception in birds, disabling their avian  magnetic compass.121 A series of double-blinded studies replicated over several  years demonstrated that migratory European robins lost their ability to orient and  navigate in a city with high background “electromagnetic noise” and broadband  frequencies.122 Effects can be complex, as illustrated by findings that some birds can  be more sensitive to weak broadband than to stronger fields.123,124  
Bees use magnetite crystals in their abdomens for navigation.125 This sensory  modality can be disrupted by electromagnetic fields, causing a loss of colony  strength.126,127,128  
Scientists are increasingly concerned about the impacts of wireless radiation on the  worldwide decline of domestic bees and colony collapse disorder.129,130  
Other insects are also adversely affected by RFR.131,132,133  
Review articles indicate that the weight of evidence is  
that RFR acts as an environmental toxin with ecosystem-wide harm  from increasing ambient RFR emitted by cell towers and  
other RFR infrastructure. 
References for the above-mentioned review articles: 134,135,136,137,138,139 
End of Clegg et al. excerpt.  
  
116 Cadiou and McNaughton 2010. https://www.ncbi.nlm.nih.gov/pubmed/20106875 117 Kirschvink, Gould 1981. https://www.ncbi.nlm.nih.gov/pubmed/7213948 
118 Ritz et al. 2004. https://www.ncbi.nlm.nih.gov/pubmed/15141211 
119 Wiltschko and Wiltschko 2014. https://www.ncbi.nlm.nih.gov/pubmed/25587420 120 Wiltschko et al. 2015. https://www.ncbi.nlm.nih.gov/pubmed/25540238 
121 Keary et al. 2009. https://frontiersinzoology.biomedcentral.com/articles/10.1186/1742-9994-6-25 122 Engels et al. 2014. https://www.ncbi.nlm.nih.gov/pubmed/24805233 123 Pakhomov et al. 2017. https://www.ncbi.nlm.nih.gov/pubmed/28794163 
124 Schwarze et al. 2016. https://www.ncbi.nlm.nih.gov/pubmed/27047356 
125 Desoil et al. 2005. https://iopscience.iop.org/article/10.1088/1742-6596/17/1/007 
126 Favre 2017. https://www.jscimedcentral.com/Behavior/behavior-2-1010.php 
127 Lambinet et al. 2017. https://www.ncbi.nlm.nih.gov/pubmed/28330921 
128 Liang et al. 2016. https://www.ncbi.nlm.nih.gov/pubmed/27005398 
129 Expert Committee. Ministry of Environment and Forest. India.2011.  
http://www.indiaenvironmentportal.org.in/content/341385/report-on-possible-impacts-of-communication towers-on-wildlife-including-birds-and-bees/ 
130 Cammaerts 2017. https://www.jscimedcentral.com/Behavior/behavior-2-1006.php 131 Cammaerts et al. 2014. https://link.springer.com/article/10.1007/s10905-014-9446-4 132 Darney et al. 2016. https://link.springer.com/article/10.1007/s13592-015-0421-7 
133 Lázaro et al. 2016. https://link.springer.com/article/10.1007/s10841-016-9868-8 
134 Kumar 2010. https://www.ee.iitb.ac.in/~mwave/GK-cell-tower-rad-report-DOT-Dec2010.pdf 135 Balmori 2005. https://www.tandfonline.com/doi/abs/10.1080/15368370500205472 136 Balmori 2015. http://www.sciencedirect.com/science/article/pii/S0048969715002296 137 Balmori and Hallberg 2007. https://www.ncbi.nlm.nih.gov/pubmed/17613041 
138 Levitt and Lai 2010. https://www.nrcresearchpress.com/doi/pdf/10.1139/A10-018?src=recsys 139 Sivani and Sudarsanam 2013. https://ecfsapi.fcc.gov/file/7520942058.pdf  
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3.3.2. Recent Scientific Reviews  
There have been several recent reviews that provide a good overview of the scientific  evidence of electromagnetic radiation and effects on wildlife.  
COMPREHENSIVE REVIEW IN 3 PARTS of the effects of electromagnetic radiation on  plants and animals at ambient levels  
This authoritative review published in 2021 stated:  
“Biological effects have been seen broadly across all taxa and  
frequencies at vanishingly low intensities comparable to today's  
ambient exposures. Broad wildlife effects have been seen on  
orientation and migration, food finding, reproduction, mating, nest and  den building, territorial maintenance and defense, and longevity and  
survivorship. Cyto- and geno-toxic effects have been observed.” 
1. Levitt, B. B., Lai, H. C., & Manville, A. M. (2021a). Effects of non-ionizing  electromagnetic fields on flora and fauna, Part 1. Rising ambient EMF levels in the  environment. Reviews on Environmental Health.  
https://doi.org/10.1515/reveh-2021-0026  
2. Levitt, B. B., Lai, H. C., & Manville, A. M. (2021b). Effects of non-ionizing  electromagnetic fields on flora and fauna, Part 2 impacts: how species interact  with natural and man-made EMF. Reviews on Environmental Health.  https://doi.org/10.1515/reveh-2021-0050  
3. Levitt, B. B., Lai, H. C., & Manville, A. M. (2021c). Effects of non-ionizing  electromagnetic fields on flora and fauna, Part 3. Exposure standards, public  policy, laws, and future directions. Reviews on Environmental Health.  https://doi.org/10.1515/reveh-2021-0083  
THREE RECENT REVIEWS ON INVERTEBRATES including pollinators.  Insect populations of critical importance for a healthy environment are declining dramatically  worldwide. These reviews are from Canada, India and Spain.  
The authors all conclude that EMR may be a contributing factor.  
1. Balmori, A. (2021). Electromagnetic radiation as an emerging driver factor for the  decline of insects. Science of The Total Environment, 767, 144913.  
https://doi.org/10.1016/j.scitotenv.2020.144913 (Spain)  
2. Friesen, M., & Havas, M. (2020). Effects of Non-ionizing Electromagnetic Pollution on  Invertebrates, Including Pollinators such as Honey Bees: What We Know, What We  don’t Know, and What We Need to Know. In Working Landscapes. Proceedings of  the 12th Prairie Conservation and Endangered Species Conference, Danyluk (ed.).  February 2019, Winnipeg, Manitoba. 203 pages. (pp. 127–138). Critical Wildlife  Habitat Program, Winnipeg, Manitoba. Retrieved from  
http://pcesc.ca/media/45404/final-2019-pcesc-proceedings.pdf (Canada)  
3. Kumar, S., Singh, V. K., Nath, P., & Joshi, P. C. (2020). An overview of  anthropogenic electromagnetic radiations as risk to pollinators and pollination.  Journal of Applied and Natural Science, 12(4), 675–681.  
https://doi.org/10.31018/jans.v12i4.2420 (India) 
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3.3.3. State of New Hampshire Report  
The State of New Hampshire formed a commission to take a deeper look at the potential  health risks of 5G. Its Commission to Study the Environmental and Health Effects of  Evolving 5G Technology published its Final Report140 in November 2020.  
The report stated that "No US agency nor international authority with expertise in science,  biology or safety has ever acted to review research and set safety limits on these non human species." and included the following among its 15 recommendations:  
STATE OF NEW HAMPSHIRE  
Commission to Study the Environmental  
and Health Effects of Evolving 5G Technology  
RECOMMENDATION 14  
The State of New Hampshire should engage agencies with appropriate scientific  expertise, including ecological knowledge, to develop RF-radiation safety limits that will  protect the trees, plants, birds, insects, and pollinators. (…)  
The State of New Hampshire needs to ensure our natural environment and wildlife are  protected by effective safety standards. Tree limbs, birds, and pollinators will be closer  than humans to 5G cell antennae and associated 4G densified infrastructure. In fact,  the wireless radiation from cell antennae is very high in a plume surrounding the  antennae. It could exceed FCC limits for several feet in this area, yet this is the exact  area where leaves of trees, birds, and pollinators live. Thus, they may have higher  exposures being in direct line of sight of wireless RF beams.  
When pollinators are impacted so are all forms of vegetation that depend on them for  reproduction. 
Appendix N of their Report lists studies and reports on the effects of wireless  radiation on trees, plants, birds, insects, pollinators, and wildlife. Among them:  
▪ A letter with background information, written by the US Department of Interior in  2014 to the National Telecommunications and Information Administration141 detailing  several published studies showing impacts of wireless radiofrequency radiation (RFR) to  birds, states that:  
The placement and operation of communication towers, including un-guyed, unlit,  monopole or lattice-designed structures, impact protected migratory birds in two  significant ways.  
The first is by injury, crippling loss, and death from collisions with towers and their  supporting guy-wire infrastructure, where present. (Attempts to estimate bird-collision  mortality at communication towers in the U.S. resulted in figures of 4-5 million bird  deaths per year (Manville 2005, 2009). A meta-review of the published literature now  suggests, based on statistically determined parameters, that mortality may be as high  as 6.8 million birds per year in Canada and the U.S.)  
  
140 Abrami et al. 2020.  
http://www.gencourt.state.nh.us/statstudcomm/committees/1474/reports/5G%20final%20report.pdf 141 https://ecfsapi.fcc.gov/file/10929811111664/41-Attachment%2041- 
%20Dept%20of%20Interior%20Original%20Letter.pdf 
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The second involves impacts from non-ionizing electromagnetic radiation emitted by  the communication towers.  
There is a growing level of anecdotal evidence linking effects of non-thermal, non ionizing electromagnetic radiation from communication towers on nesting and  roosting wild birds and other wildlife in the U.S.  
Study results have documented nest and site abandonment, plumage  deterioration, locomotion problems, reduced survivorship, and death (e.g., Balmori  2005, Balmori and Hallberg 2007, and Everaert and Bauwens 2007). Nesting migratory  birds and their offspring have apparently been affected by the radiation from  cellular phone towers in the 900 and 1800 MHz frequency ranges (…).  
In laboratory studies, T. Litovitz (personal communication) and DiCarlo et al.  (2002) raised concerns about impacts of low-level, non-thermal electromagnetic  radiation from the standard 915 MHz cell phone frequency on domestic chicken  embryos- with some lethal results (Manville 2009, 2013a). Radiation at extremely  low levels (0.0001 the level emitted by the average digital cellular telephone)  caused heart attacks and the deaths of some chicken embryos subjected to  hypoxic conditions in the laboratory while controls subjected to hypoxia were  unaffected (DiCarlo et al. 2002).  
▪ A Briefing Memorandum: What We Know, Can Infer, and Don’t Yet Know about  Impacts from Thermal and Non-thermal Non-ionizing Radiation to Birds and Other  Wildlife142 by Albert M. Manville, II, Ph.D., C.W.B.; Principal, Wildlife and Habitat  Conservation Solutions, LLC; Adjunct Professor, Johns Hopkins University’s Krieger  School of Arts and Sciences, DC Campus; and former U.S. Fish and Wildlife Service  agency lead on avian-structural impacts — including from radiation, 2016.  
▪ India dropped their RF limits to 1/10th of their previous ICNIRP-based limits after a  research review143 documented the majority of research studies found adverse effects  to wildlife, birds and bees.  
▪ Regarding bees and pollinators, the study “Exposure of Insects to Radio-Frequency  Electromagnetic Fields from 2 to 120 GHz” published in Scientific Reports found insects,  based on insect models (including the Western honeybee) can absorb the higher  frequencies that will be used in the 5G with millimetre rollout, with absorbed power  increases up to 370%. The researchers warn, “This could lead to changes in insect  behaviour, physiology, and morphology over time….” Research also has found impacts  to bees from wireless frequencies including inducing artificial worker piping (Favre,  2011), disrupting navigation abilities (Sainudeen, 2011; Kimmel et al., 2007), reducing  colony strength (Harst et al., 2006), and impacts to honey bee physiology (Kumar et al.,  2011).  
  
142 Manville, A. (2016). A BRIEFING MEMORANDUM: What We Know, Can Infer, and Don’t Yet Know about  Impacts from Thermal and Non-thermal Non-ionizing Radiation to Birds and Other Wildlife.  https://ecfsapi.fcc.gov/file/12270470130362/Manville%207-14-%202016%20Radiation%20Briefing%20Memo Public.pdf 
143 Expert Committee. Ministry of Environment and Forest. India.2011.  
http://www.indiaenvironmentportal.org.in/content/341385/report-on-possible-impacts-of-communication towers-on-wildlife-including-birds-and-bees/ 
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▪ Research on trees has found that trees can be harmed by RFR. A 9 year field study  (Waldmann-Selsam, C., et al 2016) found significant impacts to trees near cell antennas  and an investigation of 700 trees found damage starts on the side of the tree with  highest RF. A review on impacts to plants entitled, “Weak radiofrequency radiation  exposure from mobile phone radiation on plants” concluded, “a substantial amount of the  studies on RF-EMFs from mobile phones show physiological and/or morphological  effects.” A study on aspen seedlings found ambient RF in a Colorado setting were high  enough to cause necrotic lesions on the leaves, decrease leader length and leaf area,  and suppress fall anthocyanin production (Haggarty, 2010).  
▪ The European Scientific Committee on Health, Environmental and Emerging Risks states, “The lack of clear evidence to inform the development of exposure guidelines to  5G technology leaves open the possibility of unintended biological consequences.”  
3.3.4. Canada has NO regulations to protect flora and fauna from RF radiation.  What are we waiting for?  
Wireless radiation “safety” limits for birds, bees, trees, and other wildlife simply do  not exist in Canada. Canada's Safety Code 6 limits apply only to human exposures and  were not developed to protect our flora or fauna.  
And that's not all.  
There is no government agency, to our knowledge, researching or monitoring impacts of  RFR to birds, bees, trees, and other wildlife.  
The Minister of Environment and Climate Change Canada (ECCC), in his response to an  Environmental Petition to the Auditor General (October 2021),144 confirmed that:  
“Environment and Climate Change Canada is not conducting research  and monitoring activities on the potential impact of  
radiofrequency/microwave radiation exposure to biota  
to inform Health Canada or other regulatory organizations.”  
It is time to include protection for the environment from RF radiation in the Canadian  Environmental Protection Act (CEPA).  
For more on this, see the white paper entitled "Protect Birds, Bees and Trees: Include  Electromagnetic Radiation in Canadian Environmental Protection Act Amendments".  Drafted by Prevent Cancer Now and Canadians for Safe Technology. February 2022."  
  
144 Petition 456. (2021). The Government of Canada’s rigour and transparency in evaluating the science  regarding localized exposures to 5G technologies in its update of Safety Code 6. https://www.oag bvg.gc.ca/internet/English/pet_456_e_43873.html; Petition and government responses available at:  https://preventcancernow.ca/wp-content/uploads/2022/02/5G-Petition-and-Government-Response.pdf
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3.3.5. Meanwhile, plans are underway for the Internet of Underwater Things (IoUT)  
The Internet of Underwater Things is defined as a world-wide network of smart  interconnected underwater objects that enables the monitoring of vast unexplored water  areas. It includes introducing underwater devices that communicate long-distance through  impactful acoustic waves — deafening marine life — as well as installing nodes and devices  at the ocean floor, scattering numerous underwater vehicles and robots all over the oceans,  creating electromagnetic interferences, and much more.145 
The US Defense Advanced Research Projects Agency (DARPA) has awarded a contract for  the next phase of development of its Ocean of Things (OoT), a project to seed the seas  with thousands of floating sensors, monitoring everything that passes from aircraft to  submarines. The name is a play on the Internet of Things and the aim is to achieve  persistent maritime situational awareness over large ocean areas.146 Data from this floating  distributed network will support US Department of Defense missions as well as public  oceanographic research and commercial applications.  
At a time when so many species are struggling  
to survive climate change, habitat loss, pesticides, poaching  and other harms perpetrated by our species,  
it is crucial that we learn more  
about how wireless technology is impacting them,  
and that we apply the brakes before it is too late.  
  
145 New Threat To Life: The Internet Of Underwater Things. Verve Times, Feb 12, 2022.  https://vervetimes.com/new-threat-to-life-the-internet-of-underwater-things/ 
146 DARPA Progress With ‘Ocean Of Things’ All-Seeing Eye On The High Seas. Forbes, Aug 13, 2020.  https://www.forbes.com/sites/davidhambling/2020/08/13/darpas-ocean-of-things-is-an-all-seeing-eye-on-the high-seas/?sh=65491ff3f270 
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3.4. A Major Contributor to Climate Change and Pollution  
“The communications industry could use 20% of all the world’s electricity by 2025, hampering attempts to meet climate change targets and straining grids as demand  by power-hungry server farms storing digital data from billions of smartphones,  tablets and internet-connected devices grows exponentially.  
The industry has long argued that it can considerably reduce carbon  
emissions by increasing efficiency and reducing waste,  
but academics are challenging industry assumptions.”  
The Guardian, 2017147 
3.4.1. 5G is not sustainable – plain and simple  
In an article published by the Institute for Electrical and Electronics Engineers (IEEE),  researchers from the University of Melbourne stated:  
"Wireless technologies will continue to consume  
at least 10 times more power than wired technologies  
when providing comparable access rates and traffic volumes.”148 
It was estimated that from 2012-2015, the wireless cloud would increase its carbon footprint  by the equivalent of adding 4.9 million cars to the road.149  
∙ One 5G base station is expected to consume roughly three times as much power  as a 4G base station.150  
∙ And 5G is expected to require far more base stations to deliver service and connect  billions of mobile and IoT devices.151  
The three main ways energy is consumed for Information Communications Technology are:  
1) Embodied energy (energy associated with the manufacturing of a product, from the extracting and  processing of raw materials, to manufacturing, transportation, distribution, assembly and construction)  2) Data centers  
3) Obsolescence of digital technologies, e.g., e-waste  
Artificial intelligence with its complex algorithms also adds significantly to the carbon  footprint of ICT. "Behind every voice assistant like Amazon’s Alexa is a network of  algorithms that help the voice assistant understand and interact with us. Behind every voice  assistant are also hundreds of thousands of pounds of CO2 emissions."152 
  
147 The Guardian (Dec 11, 2017). Tsunami of data’ could consume one fifth of global electricity by 2025.  https://www.theguardian.com/environment/2017/dec/11/tsunami-of-data-could-consume-fifth-global-electricity-by 2025#:~:text=The%20communications%20industry%20could%20use,internet%2Dconnected%20devices%20grows%20ex ponentially. 
148 Baliga, J., Ayre, R., Hinton. K., & Tucker, R. (2011). Energy Consumption in Wired and Wireless Access  Networks. IEEE Communications Magazine, June 2011, p. 76 https://ieeexplore.ieee.org/document/5783987 https://people.eng.unimelb.edu.au/rtucker/publications/files/energy-wired-wireless.pdf 149 https://ceet.unimelb.edu.au/publications/ceet-white-paper-wireless-cloud.pdf. p. 14 150 Koziol, Michael. (2019). 5G’s Waveform Is a Battery Vampire. IEEE Spectrum, July 24, 2019 https://spectrum.ieee.org/5gs-waveform-is-a-battery-vampire 
151 Ibid.  
152 https://envirobites.org/2019/09/10/alexa‐whats‐your‐carbon‐footprint/
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3.4.2. Large consumers of energy – from production to usage  
A study from McMaster University published in the Journal of Cleaner Production, assessed  the global carbon footprint of the Information and Communication Technology Industry  (ICT), including the contribution from the main consumer devices, the data centers and  communication networks, and compared it with total worldwide global greenhouse gas  emissions (GHGE).  
They found that the ICT Industry global greenhouse gas emissions are projected to “exceed  14% of the 2016-level worldwide GHGE by 2040, accounting for more than half of the  current relative contribution of the whole transportation sector”.153  
Trends suggest that of all devices,  
smartphones will be the most  
damaging to the environment.  
While they consume little energy to  
operate, 85% of their emissions  
impact comes from production. The  
McMaster study predicted that by  
2020 the footprint of smart phones  
alone would surpass the individual  
contribution of desktops, laptops and  
displays. A smartphone’s chip and  
motherboard require the most  
amount of energy to produce as they  
are made up of precious metals that  
are mined at a high cost.  
“ In absolute terms, the GHGE  
emissions of smart phones grew 
from about 17 Mt-CO2-e in 2010 to  
125 Mt-CO2-e in 2020,  
representing a 730% increase in  
the span of 10 years. This impact  is clearly driven by the fact that the  production energy makes up 85- 95% of its lifecycle annual foot print, driven by the short average  
Largest impact comes from the data centres.  Among the devices, smartphones expected to be  the most damaging  
Source: Belkhir, L. & Elmeligi, A. (2018). See footnote below.  
useful life of smart phones of 2 years, which is driven by the telecom membership  business model. Clearly this business model, while highly profitable to the smart  phone manufacturers and the telecom industry, is unsustainable and quite  detrimental to the global efforts in GHGE reductions.  
—Belkhir and Elmeligi (2018)154  
  
153 Belkhir, L. & Elmeligi, A. (2018). Assessing ICT global emissions footprint: Trends to 2040 &  Recommendations. Elsevier, Journal of Cleaner Production, 177, 448-463.  
https://www.sciencedirect.com/science/article/pii/S095965261733233X 
154 Belkhir, L. & Elmeligi, A. (2018). Assessing ICT global emissions footprint: Trends to 2040 &  Recommendations. Elsevier, Journal of Cleaner Production, 177, 448-463.  
https://www.sciencedirect.com/science/article/pii/S095965261733233X
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Wireless access dominates data centre consumption  
 “For every text message, for every phone call, every video you upload  or download, there’s a data center making this happen.  
Telecommunications networks and data centers consume a lot of energy to serve  you and most data centers continue to be powered by electricity generated by fossil  fuels. It’s the energy consumption we don’t see.”  
-- Lotfi Belkhir, PhD, Faculty of Engineering, McMaster University  
Data centres are huge  
warehouses where  
thousands of computers  
are stacked row after row  
and operate 24/7 to  
process and store data.  
They use massive  
amounts of electricity to  
store everything sent  
through the internet.  
They also require cooling  
to function, which  
consumes even more  
electricity.  
According to a white paper published by the Centre for energy-efficient telecommunications,  Bell Labs and University of Melbourne, “The energy consumption of wireless access  dominates data centre consumption by a significant margin.”155  
The McMaster study agrees:  
“Most of that relative growth comes from the data center industry, which  as we move increasingly into a digital age, has become the backbone of  both the Internet as well as the telecom industry, and grew its contribution  to the overall footprint from 33% in 2010 to 45% in 2020.  
In absolute terms, it shows an almost 3-fold increase from 159 to 495  Mt-CO2-eq in the 10-year span.”  
Researchers have been warning us that 5G will force the expansion of the data centre  industrial complex.  
"5G will massively increase the amount of new data needing storage,  including from thousands of new satellites and the many "smart" devices  being sold to the public."156 
According to the same article, "currently, a new data centre usually uses about 30  megawatts of electricity – enough to power a small city."  
  
155 The Power of the Wireless Cloud: An analysis of the impact on energy consumption of the growing  popularity of accessing cloud services via wireless devices. CEET – Centre for energy-efficient  telecommunications, Bell Labs and University of Melbourne https://ceet.unimelb.edu.au/publications/ceet white-paper-wireless-cloud.pdf 
156 Nelson, J.. 5G and the Canadian Data Centre Rush: Between the power needs of 5G itself and the power  needed to store vast amounts of new data, will Canadian ratepayers and municipalities be left holding the  bag?. Watershed Sentinel. October 5, 2021. https://watershedsentinel.ca/articles/the-power-pull-of-5g/
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3.4.3. E-Waste will increase substantially with 5G  
Only 20% of e-waste is recycled today.157 
E-waste causes significant environmental harm and will increase substantially with 5G.  
5G will require millions of new cellular antennas called “small cells” – basically shorter  cell towers – close to our homes, as well as more large cell towers. The industry calls this  “densification”. These 5G antennas will connect with billions of new wirelessly connected  “smart” devices referred to as the Internet of Things (IOT). See section 2.6. 
In addition, there are no upgrade solutions that will allow 4G cell phones to work with 5G  networks in Canada. Everyone who wants 5G service will need to buy a new phone, and  will therefore discard their old ones.  
Smartphones have a short life that drives further production of new models and an  extraordinary amount of waste. The average smartphone life cycle in the United States is  now under three years158 and there are more mobile phone subscriptions and handsets (7.7  billion) globally than there are people on Earth (7.4 billion).159  
3.4.4. High social and environmental costs  
Smartphones can contain as many as 50 different elements, including minerals linked to  civil unrest, rare earth metals whose availabilities are dwindling, and various toxic materials  that can degrade the natural world and threaten public health.160 The social and physical  costs of cell phones and smart phones is higher than most people realize and higher than  many would be willing to pay if they were aware of the real costs.161 
3.4.5. Space Junk  
Of the thousands of satellites currently circling our planet, close to 60% are defunct,  i.e., space junk.  
As the number of satellites being launched for Internet access and the IoT connectivity  skyrockets (see section 2.3.3), so will space debris increase.162 
Source: Visual Capitalist https://www.visualcapitalist.com/visualizing-all-of-earths-satellites/ 
  
157 https://www.itu.int/en/mediacentre/backgrounders/Pages/e-waste.aspx 
158 https://www.statista.com/statistics/619788/average-smartphone-life/ 
159 https://www.telegraph.co.uk/science/2017/12/13/discarded-phones-computers-electronics-behind-worlds fastest/ 
160 https://www.sciencedaily.com/releases/2018/10/181016142434.htm 
161 https://digital.sandiego.edu/cgi/viewcontent.cgi?article=1012&context=honors_theses 162 https://www.marketwatch.com/story/elon-musk-is-polluting-the-skies-with-spacexs-thousands-of-satellites 2020-05-27
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3.5. Risks to Personal and Business Privacy  
The Internet of Things (IoT) brings with it grave concerns about privacy.  
5G networks will transmit exponentially more data, providing an opportunity to collect,  process, harvest and use it for commercial, or for nefarious purposes.  
Targeted advertising is only the tip of the iceberg.  
Thanks to neural networking and machine learning algorithms, computers now routinely  recognize images, parse and respond to human speech, answer questions and make  decisions. Companies can work with data derived from GPS sensors, Bluetooth beacons  and other sources.  
We are constantly and inadvertently providing data whenever we surf the internet, give a  voice command to "Alexa", make a credit card purchase, give our email address to a store,  or sign up on a website. This information can be shared and compiled to create profiles.  
Sensitive information can easily be transferred, leaked, or hacked.  Information such as...  
Your health information  
Digitized medical records, data obtained in the process of paying for prescriptions, not to  mention the information we unthinkingly provide every time we use a search engine to  find information about a disease, or post online about an illness or condition, our worries,  or our favourite foods, how much we exercise, and much more.  
Your movements  
Canadians would surely protest if the government ordered every person to carry a  tracking device that revealed their location 24 hours a day. Yet, in the past 10 years,  app by app, people have been consenting to just such a system run by private  companies that are far less accountable than governments.  
Companies are collecting precise movements using software on mobile phone apps.163  
Anyone with access to this data can see where you go, with whom you meet,  with whom you sleep, where you pray, whether you visit a clinic, a gym, a  psychiatrist’s office or a massage parlor.  
From this information, evidence can be obtained about health problems, drug addiction,  marital problems, visits to psychiatrists; they can learn whether you are religious,  whether you participated in a protest, and much more.  
The Electronic Frontier Foundation (https://www.eff.org/) offers some in-depth analysis of  privacy and security issues.164  
  
163 Zuboff, S. (2014, January). The Age of Surveillance Capitalism published by Public Affairs, Hachette Book  Group  
164 EFF is an independent non-profit that has been working to protect online privacy for nearly thirty years. 
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The report from The New York Times Privacy Project,165 demonstrates in an  interactive way what they discovered. Click on this link. It is eye-opening.  
One Nation, Tracked: An Investigation Into the Smartphone Tracking  
Industry from Times Opinion 
"Every minute of every day, everywhere on the planet, dozens of companies --  largely unregulated, little scrutinized -- are logging the movements of tens of millions  of people with mobile phones and storing the information in gigantic data files.  
The Times Privacy Project obtained one such file, by far the largest and most  sensitive ever to be reviewed by journalists. It holds more than 50 billion location  pings from the phones of more than 12 million Americans as they moved through  several major cities. (...) The sources of the information (employees at a location data  company) said they had grown alarmed about how it might be abused and urgently  wanted to inform the public and lawmakers.  
After spending months sifting through the data, tracking the movements of  people across the country and speaking with dozens of data companies,  technologists, lawyers and academics who study this field, we feel the same  sense of alarm."  
-- Twelve Million Phones, One Dataset, Zero Privacy, By Stuart A. Thompson  and Charlie Warzel, The New York Times, Dec. 19, 2019  
3.6. Grave Security Risks  
5G networks will transmit exponentially more data wirelessly, increasing the risk to  personal and business privacy along with broader cybersecurity risks.166,167 
Wireless networks are less secure, and more prone to hacking than wired systems.168 
  
165 https://www.nytimes.com/interactive/2019/12/19/opinion/location-tracking-cell-phone.html 166 https://www.eff.org/ 
167 N. Patel, “Wait, why the hell is the ‘race to 5G’ even a race?” in The Verge, May 23, 2019.  https://www.theverge.com/2019/5/23/18637213/5g-race-us-leadership-china-fcc-lte 
168 Timothy Schoechle, Re-Inventing Wires: The Future of Landlines and Networks. Washington, DC: National  Institute for Science, Law and Public Policy, 2018. https://electromagnetichealth.org/wp content/uploads/2018/05/Wires.pdf
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The network layer will need to use more complex software and more resources, like cloud  services, to function. The number of network antennas will increase by a factor of 20, and  with the IoT, many will be poorly secured ‘things’ such as household appliances.  
Click here: https://www.youtube.com/watch?v=ZPsnWKxeyIo&feature=youtu.be for a 3-minute video by Oxford Information Labs that explains why 5G networks will be more  susceptible to attack than previous mobile networks. 
Every part of the supply chain can be attacked.  
According to Bruce Schneier, an internationally renowned security technologist, lecturer at  Harvard's Kennedy School who has been called a "security guru" by The Economist, "Every  part of the supply chain can be attacked when it comes to 5G technology; we have to build  a trustworthy system out of untrustworthy parts."169 
"Back doors" can be installed into the product. The computers, devices, smartphones,  the chips that are inside them, the engineers who design and program them – come from  over a hundred countries. "Thousands of people have the opportunity, acting alone, to slip a  back door into the final product." says Schneier. In addition, open-source software  packages are increasingly targeted by groups installing back doors.  
Attacks can be launched through software distribution systems (fake apps illustrate  this); through update systems (The NotPetya worm was distributed by a fraudulent update  to a popular Ukrainian accounting package); and through freely available software code  libraries (where malicious code can be inserted, then unintentionally used by programmers  around the world).  
And while potential nation-state threats like China and Huawei make the news, many  of these vulnerabilities are also being exploited by cybercriminals.  
The Internet of Things (IoT) will act like an unprotected back door.  
∙ In 2000, Russian anti-virus company Kaspersky Lab warned that in a few years Internet connected fridges and other household appliances will be targets of net viruses.170 ∙ In 2014, the California security firm Proofpoint, Inc. announced that it discovered a large  “botnet” which infected an internet-connected refrigerator, as well as other home appliances,  and then delivered more than 750,000 malicious emails.171  
∙ In 2015, security company Pen Test Partners discovered a vulnerability in the internet connected refrigerator Samsung model RF28HMELBSR that can be exploited to steal Gmail  users' login credentials.172  
“The world uses one network, and there can only be one answer:  
Either everyone gets to spy, or no one gets to spy.  
And as these systems become more critical to national security,  
a network secure from all eavesdroppers becomes more important.”  
– Bruce Schneier 
  
169 Bruce Schneier (2019). Essays: Every Part of the Supply Chain Can Be Attacked - Schneier on Security.  The New York Times, Sept 25, 2019 
https://www.schneier.com/essays/archives/2019/09/every_part_of_the_su.html 
170 Linda Harrison, "Fridges to be hit by Net viruses," in The Register, 21 June 2000  171 "Fridge sends spam emails as attack hits smart gadgets". BBC News. 17 January 2014. 172 Colin Neagle, "Smart refrigerator hack exposes Gmail account credentials" in Network World (26 August  2015). Retrieved 23 October 2016.  
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3.7. Contravention of Human Rights  
People have not given their fully informed consent to the potential risks to their  health of exposure to 5G technologies.  
Basic human rights are being infringed because  
∙ the general public is generally not aware of any of the potential health risks. Making  matters worse, Health Canada’s website is misinforming Canadians.173  
∙ most small cell antennas for the 5G network will not require public notification.  Small antennas are being placed on lamp posts, hydro poles, on the sides and tops of  buildings without notice, public consultation or identifying signage; some are even  deliberately hidden.174 
∙ the Canadian government (ISED and the CRTC) are quietly allowing (and funding)  companies to blanket Canadians with RF radiation 24/7 from thousands of Low  Earth Orbit satellites. (See 2.3.3)  
∙ citizens (and their local governments) cannot prevent the installation of these  antennas. 
Public notification (and consultation) are not required for175:  
∙ The installation of antennas on “Non-Tower Structures” (buildings, water towers, lamp  posts, etc.) provided that the height of the structure is not increased by more than 25%.  ∙ Height increases of up to 25% on existing cell towers.  
It should be noted that while a public consultation is required for the installation of all new  cell towers, notification of the wider community is only required for towers 30 metres or more  in height (see section 5.2).  
A Danish attorney, Christian F. Jensen, has examined whether the establishment of a 5G  system would be a contravention of human rights and environmental law. The conclusion is  that  
  
‘’establishing and activating a 5G-network, as it is currently described, would be in  contravention of current human and environmental laws enshrined in the European  Convention on Human Rights, the UN Convention on the Rights of the Child, EU  regulations, and the Bern- and Bonn-conventions.‘’176 
Canada ratified the UN Convention on Rights of the Child in 1991.177 The Canadian  Human Rights Commission (CHRC) has a policy on Environmental Sensitivities.178 Although electromagnetic hypersensitivity (EHS, commonly called electrosensitivity) is not  specifically mentioned in the policy, it is included in the accompanying CHRC report Medical  Perspective on Environmental Sensitivities.179 
  
173 Canadians for Safe Technology (2020). C4ST Fact-checks Government of Canada Webpages Regarding  Health Risks and Wireless Technologies, including 5G. docs.c4st.org/C4STdocs/C4ST-Factchecks-GoC websites.pdf 
174 https://www.ericsson.com/en/networks/offerings/urban-wireless/invisible-sites 
175 https://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf10840.html Section 2.4  
176 https://mdsafetech.files.wordpress.com/2019/07/5g-danish-legal-opinion-jensen-2019.pdf 177 https://www.justice.gc.ca/eng/rp-pr/fl-lf/divorce/crc-crde/conv2a.html 
178 https://www.chrc-ccdp.gc.ca/eng/content/policy-environmental-sensitivities 
179 https://www.chrc-ccdp.gc.ca/eng/content/medical-perspective-environmental-sensitivities [accessed 14Feb  2020]. 
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3.8. Decreased Ability to Forecast the Weather and Monitor the Climate,  and a Threat to Astronomical Observation  
"What if, suddenly, decades of progress in weather prediction was reversed  and monster storms that we currently see coming for days were no longer  foreseeable? The toll on life, property and the economy would be enormous.  Yet the government’s science agencies say such a loss in forecast accuracy  could happen if the Federal Communications Commission and  
the U.S. wireless industry get their way."  
– Jason Samenow, Washington Post, May 23, 2019.  
5G Deployment Could Set Weather Forecasting Back 40 Years.  
Scientists have warned that 5G technology could interfere with critical satellite data  which could result in a 30% reduction in weather forecast accuracy.180 
5G intends to use the 24 GHz band which could interfere with the microwave sensors that  transmit important water vapor data at a frequency of 23.8 GHz. This valuable data is  transmitted from satellites, weather balloons, ocean buoys, weather radars and other  technologies that are used by government agencies and the private sector.  
The US government’s science agencies, National Oceanic and Atmospheric Administration  (NOAA) and National Aeronautics and Space Administration (NASA), have expressed  serious concerns over this issue. Testifying before the House Science Committee on May  16, 2019, Neil Jacobs, the acting head of the NOAA, told members of Congress that the  interference could result in a 30% reduction in forecast accuracy. "With this reduced  forecast skill, the European model would not have predicted 2012′s Superstorm Sandy  hitting the Northeast coast several days in advance", Jacobs said. Lead time to prepare for  the storm would have been cut short.  
In a memo on March 27, 2019, the US Navy also stated that the data interference would  lead to “a probable degradation of weather and ocean models, resulting in increased risk in  Safety of Flight and Safety of Navigation, and degraded Battlespace Awareness for tactical /  operational advantage.”  
“NASA took us to the moon, and NOAA helped us explore the depths of the ocean.  We rely on these agencies for scientific expertise, and they have warned us about the dire  impact of this spectrum sale on weather forecasting capabilities — we should listen.”  -- Sen. Maria Cantwell (D-Wash.) in a statement to The Washington Post  
Possible Risk to Climate Monitoring  
Jacobs added that if the data loss from interference reaches just 2 percent, NOAA would  likely have to “stop work” on its $11 billion polar-orbiting satellite program, important for  not just weather forecasting but also for climate monitoring and many other  applications.181 
  
180 https://www.washingtonpost.com/weather/2019/05/23/head-noaa-says-g-deployment-could-set-weather forecasts-back-years-wireless-industry-denies-it/ 
181 https://www.washingtonpost.com/weather/2019/05/23/head-noaa-says-g-deployment-could-set-weather forecasts-back-years-wireless-industry-denies-it/
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The Night Sky and Astronomical Observation Endangered  
The deployment of an estimated 42,000 satellites over the next year are not only an  unprecedented source of light pollution, but also threaten ground-based  astronomy.182,183  
They will greatly outnumber the approximately 9,000 stars that are visible to the unaided  human eye. This will deprive humanity of an unblemished view of the night sky.  Astronomical observations have led to exceptional progress in our understanding of the Laws  of Nature, and to scientific advances in industry, aerospace, energy, medicine and more.  
See section 2.3.3 for more on these satellites.  
As of February 26, 2022, over 2,000 astronomers had signed an appeal warning that  astronomical observations will be greatly impaired by the deployment of large satellite fleets  in preparation for 5G. The Starlink satellite array, unlike previous satellites, is  unprecedented. Besides the sheer number, they are much brighter, are configured to be in  a series of intersecting trains, and are designed to be in orbits that require constant course correcting. Under these conditions, the identification and measurement of transient and  variable events, such as supernovae, flares, and variable stars, will become impossible.  Also, asteroid monitoring to guard the Earth from potential impact events, would be  negatively impacted and affect astronomers' ability to warn humankind. Click here to read  the Astronomers' Appeal. (https://astronomersappeal.wordpress.com)  
As astronomer Caitlin Casey stated,  
"The fact that one person, or one company, can take control and  
completely transform humans’ experience of the night sky, and not just humans,  but every organism on Earth … that seems profoundly wrong."  
3.9. Major Risk to Aviation Safety  
According to a white paper184,185,186 published in 2020, the RTCA, a private-public aviation  partnership that advises the US Federal Aviation Administration, warns that 5G technologies  could pose a "major risk…of harmful interference" to radar on business jets and other  civilian aircraft. If 5G telecommunications systems are permitted to use that frequency band  (3.7-3.98 GHz), said the report, "the risk is widespread and has the potential for broad  impacts to aviation operations in the US, including the possibility of catastrophic failures  leading to multiple fatalities, in the absence of appropriate mitigations." 
Canada will be auctioning that frequency band in early 2023. 
  
182 https://www.forbes.com/sites/startswithabang/2020/01/30/dangers-to-astronomy-intensify-with-spacexs latest-starlink-launch/#6c15e6476a57 
183https://astronomersappeal.wordpress.com/?fbclid=IwAR0aYFp4cxE1E84zis7Qt4p1kum3qe_EuK43gINN8_ ZJbrxkuETlsBvDgWA 
184 News Release: White Paper on 5G Interference Impact on Radar Altimeter Operations, October 8, 2020.  https://www.rtca.org/news/rtca-announces-new-white-paper-on-5g-interference-impact-on-radar-altimeter-operations/ 185 Assessment of C-Band Mobile Telecommunications Interference Impact on Low Range Radar Altimeter  Operations, White Paper, October 7, 2020. https://www.rtca.org/wp-content/uploads/2020/10/SC-239-5G Interference-Assessment-Report_274-20-PMC-2073_accepted_changes.pdf 
186 https://robbreport.com/motors/aviation/5g-interfere-airplane-radar-1234580467/?fbclid=IwAR30J grQkFRot9OW_k9FG7HWcUr3UtFvC8FQL9_CCffMeWCJlfljldgwok
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Radar altimeters are the only aircraft sensors that measure the height of the aircraft above the  terrain. According to the Flight Safety Foundation, altimeters provide critical information to  terrain awareness and warning systems (TAWS), traffic-alert and collision avoidance systems  (TCAS), wind shear detection systems, flight control systems and autoland systems. The  measurements from radar altimeters are also used by electronic centralized aircraft  monitoring (ECAM) systems and engine-indicating and crew alerting systems (EICAS).  
UPDATE: The federal government recently announced plans to restrict 5G service near major  airports citing concerns about possible interference.187 
3.10. Increased Economic Burden  
The economic burden of wireless technologies has never been evaluated.188  While the benefits have been widely discussed, the actual costs have never been assessed  to determine if they outweigh the benefits.  
∙ Canadian doctors raised concerns about the economic burden of increased health  care costs. At a 2019 symposium hosted by the Environmental Health Clinic, Women’s  College Hospital in Toronto, scientists and physicians stated that 5G rollout will expose  Canadians to an unprecedented increase in radiofrequency radiation189 and expressed  concern that our health care costs will rise without our medical professionals’ having the  necessary information for making adjustments.190 
∙ The costs to our sustainability have never been evaluated.  
The Minister of Environment and Climate Change Canada (ECCC), in his response to an  Environmental Petition to the Auditor General (October 2021), confirmed that: ECCC “is  not examining energy and resources implications to sustainability and climate change  from the use of various alternative technologies for telecommunications.”191 
All of the risks described in this chapter will translate into tangible costs to society:  ∙ healthcare and lost productivity related to adverse health effects from RF radiation  ∙ costs engendered by security192 and privacy breaches,193  
∙ environmental damage  
∙ the impacts to safety and property from the degradation of weather forecast accuracy  and climate monitoring.  
  
187 Ottawa stuns telecoms with surprise announcement that Canadians living near airports won’t get full 5G  service. Toronto Star. Sat., Oct. 9, 2021. https://www.thestar.com/business/2021/10/09/ottawa-stuns telecoms-with-surprise-announcement-that-canadians-living-near-airports-wont-get-full-5g-service.html 188 Patel, N. (2019, May 23). Wait, why the hell is the ‘race to 5G’ even a race?  
https://www.theverge.com/2019/5/23/18637213/5g-race-us-leadership-china-fcc-lte 
189 Women’s College Hospital, Toronto. (31 May2019). Impacts of Wireless Technology on Health: A  symposium for Ontario’s medical community. https://www.womenscollegehospital.ca/care programs/environmental-health-clinic/june-2019-conference-videos 
190 Media Release - Ontario Doctors Warn of Rising Health Care Costs after 5G Roll Out  https://www.youtube.com/watch?time_continue=4&v=S16QI6-w9I8 
191 Petition 456. (2021). The Government of Canada’s rigour and transparency in evaluating the science  regarding localized exposures to 5G technologies in its update of Safety Code 6. https://www.oag bvg.gc.ca/internet/English/pet_456_e_43873.html; Petition and government responses available at:  https://preventcancernow.ca/wp-content/uploads/2022/02/5G-Petition-and-Government-Response.pdf 192 Schneier, B. (2019, September 25). Essays: Every Part of the Supply Chain Can Be Attacked - Schneier  on Security. https://www.schneier.com/essays/archives/2019/09/every_part_of_the_su.html 193 The Threat Lab. (2019, June 26). The History of Cellular Network Security Doesn’t Bode Well for 5G.  https://www.eff.org/deeplinks/2019/06/history-cellular-network-security-doesnt-bode-well-5g
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4. Scientists and Doctors Have Been Warning  Governments for Years  
4.1. The International EMF Scientist Appeal to the UN (ongoing)  
"Based upon peer-reviewed, published research, we have serious concerns regarding  the ubiquitous and increasing exposure to electromagnetic fields generated by  electric and wireless devices. These include – but are not limited to – radiofrequency  radiation (RFR) emitting devices, such as cellular and cordless phones and their base  stations, Wi-Fi, broadcast antennas, smart metres, and baby monitors as well as  electric devices and infra-structures used in the delivery of electricity that generate  extremely-low frequency electromagnetic field (ELF EMF)."  
World-recognized scientists engaged in the study of biological and health effects of non ionizing electromagnetic fields (EMF) are urgently calling upon the United Nations and  its sub-organizations, the World Health Organization (WHO) and the United Nations  Environment Programme (UNEP), and all UN Member States, for more protective  standards regarding RF radiation.194 These scientists specialize in evaluating the  scientific evidence connecting RF radiation and harm to humans.  
The original appeal was submitted on May 11, 2015. On July 22, 2019, it was resubmitted to  the United Nations Environment Programme (UNEP) Executive Director, Inger Andersen,  requesting the UNEP reassess the potential biological impacts of next generation 4G and  5G telecommunication technologies to plants, animals and humans. 
As of January 14, 2021: 255 EMF scientists from 44 nations had signed.  To read the Appeal: https://www.emfscientist.org/ 
(These scientists have over 2,000 studies on non-ionizing radiation published in the  peer-reviewed literature.)  
4.2. Scientists' 5G Appeal to the European Union (ongoing)  
"We the undersigned, recommend a moratorium on the rollout of the fifth generation, 5G,  for telecommunication until potential hazards for human health and the environment  have been fully investigated by scientists independent from industry.  
5G will substantially increase exposure to radiofrequency electromagnetic fields (RF EMF) on top of the 2G, 3G, 4G, Wi-Fi, etc. for telecommunications already in place.  RF-EMF has been proven to be harmful for humans and the environment."  
The 5G Appeal was launched in 2017 by scientists and doctors who are urgently calling  on the European Union to halt the rollout of 5G due to serious potential health effects  from this new technology.195 
As of January 24, 2022: 421 scientists and medical doctors from 49 nations had signed.  To read the Appeal: https://www.5gappeal.eu/the-5g-appeal/ 
  
194 International EMF Scientists Appeal. https://www.emfscientist.org/ 
195 5G Appeal http://www.5gappeal.eu/
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4.3. Consensus Statement of UK and International Medical and  Scientific Experts and Practitioners on Health Effects of  
Non-Ionising Radiation (NIR) (ongoing)  
"We the undersigned state that the (…) ‘Urgent Action Points’ must be addressed  immediately by the UK Government and other governments internationally,  in order to prevent avoidable human injury, disease, deaths and  
potentially irreversible environmental damage.  
People must be allowed to retain the right not to be exposed against their will." 
Launched in 2020, this 12-page document declares current safety levels to be inadequate and  highlights some of the disease processes linked with NIR exposure in peer-reviewed publications;  it points out the vulnerabilities of children and other hypersensitive groups; it also highlights the  contravention of Human Rights and Equalities acts and requests urgent responses from  governments and health authorities to halt further deployment of emitting technology and address  current public health failures.196 
To read the Statement: https://phiremedical.org/wp-content/uploads/2020/11/Press-Release-2020- Non-Ionising-Radiation-Consensus-Statement-1.pdf 
Endorsed so far by the following groups representing over 3,500 medical doctors,  including experienced clinicians and widely-published experts in this field  
∙ Physicians’ Health Initiative for Radiation and Environment  ∙ British Society for Ecological Medicine  
∙ Alborada Foundation (Spain)  
∙ American Academy of Environmental Medicine  ∙ Australian College of Nutritional and Environmental  Medicine  
∙ European Academy for Environmental Medicine  ∙ Italian Association of Doctors for the Environment 
∙ National Association of Environmental Medicine (USA)  ∙ Ralf Meyer Akademie für Komplementärmedizin  ∙ Kompentenzinitiative (Germany)  
∙ EM Radiation Research Trust  
∙ Environmental Health Trust  
∙ International EMF Alliance  
∙ International Guidelines on Non-Ionising Radiation  ∙ Oceania Radiofrequency Scientific Advisory Association 


  
196 2020 Consensus Statement of UK and International Medical and Scientific Experts and Practitioners on  Health Effects of Non-Ionising Radiation (NIR)
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4.4. International Appeal to Stop 5G on Earth and in Space (ongoing)  
"We the undersigned scientists, doctors, environmental organizations and citizens from  __ countries, urgently call for a halt to the deployment of the 5G (fifth generation)  wireless network, including 5G from space satellites. 5G will massively increase  exposure to radio frequency (RF) radiation on top of the 2G, 3G and 4G networks for  telecommunications already in place. RF radiation has been proven harmful for humans  and the environment. The deployment of 5G constitutes an experiment on humanity and  the environment that is defined as a crime under international law."  
This appeal, addressed to the United Nations, the World Health Organization, the  European Union, the Council of Europe, and governments of all nations, and  signed by scientists, doctors, environmental organizations and citizens, urgently calls  for a halt to the deployment of the 5G (fifth generation) wireless network, including 5G  from space satellites. 
As of February 26, 2022: 300,675 signatories from 215 nations and territories,  including 4,388 medical doctors  
To read the Appeal: https://www.5gspaceappeal.org/the-appeal 
4.5. United States of America National 5G Resolution  
 “We join with the thousands of doctors, scientists and health care providers worldwide  who have recently issued appeals for urgent action on 5G to protect public health and  call for a moratorium on 5G and any further wireless antenna densification until  potential hazards for human health and the environment have been fully  investigated by scientists independent from the wireless industry.”  
“The children are our future. The scientific evidence has been clear for decades and  now America has an opportunity to lead the way,” said Toril H. Jelter, MD, a pediatrician  who presented at the EMF Conference with case studies on children she has treated  who have dramatically improved after reducing wireless exposures. “It is my impression  that health effects of wireless radiation go misdiagnosed and underdiagnosed for years.  Parents, teachers and physicians need to know that hardwiring internet, phone and tv is  a healthier option for our children.”  
This letter to President Trump signed by American scientists, doctors and healthcare  practitioners, urgently calls for a moratorium on the rollout of 5G until potential  hazards for human health and the environment have been fully investigated by  scientists independent from the industry. The letter references the published scientific  studies demonstrating harm to human health, bees, trees and the environment from current  wireless technology and posits that 5G will both increase exposure and add in new  technology never safety tested for long-term exposure.  
(Developed during the first three-day US medical conference fully dedicated to this  topic, Electromagnetic Fields Conference on Diagnosis and Treatment, which convened in  Scotts Valley, California in September 2019.)  
As of December 2019: 113 doctors and health practitioners had signed  To read the Appeal: https://www.globalresearch.ca/dozens-us-doctors-healthcare practitioners-send-letter-president-trump-calling-moratorium-5g-press-release/5698191
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4.6. Appeals Between 1998 and 2014  
The recent appeals are nothing new. For over 20 years, scientists and doctors have been  warning governments around the world. Each of these appeals, resolutions and statements  were endorsed by a group of experts.  
• Doctors’ Declaration to Health Canada  2014197 
• Scientists’ Declaration to Health Canada  2014198 
• Potenza Picena Resolution (Italy) 2013  • International Doctors' Appeal 2012  
• The Karolinska Institute, Stockholm,  Sweden, 2011 (Press release: “Scientists Urge  Halt of Wireless Rollout and Call for New Safety  Standards: Warning Issued on Risks to Children  and Pregnant Women”199)  
• Seletun Consensus Statement 2011 (Panel  of international scientists (Norway, Israel, USA,  Sweden, Russia & Greece)200 
• International Appeal of Würzburg 2010  • Copenhagen Resolution 2010  
• Paris Appeal 2009 (Déclaration du 23 mars  2009: Champs électromagnétiques et santé)  
• Porto Alegre Resolution 2009  
• Dutch Appeal 2009  
• Venice Resolution 2008  
• Berlin Appeal 2008  
• London Resolution 2007  
• Schlüchterner Appeal, Germany 2007 (39  MDs)  
• Brussels Appeal 2007  
• Benevento Resolution 2006  
• Allgäuer Appeal 2006  
• WiMax Appeal 2006  
  
197 http://www.c4st.org/images/documents/hc resolutions/medical-doctors-submission-to-health canada-english.pdf 
198 http://www.c4st.org/images/documents/hc resolutions/scientific-declaration-to-health-canada english.pdf 
199 https://ecfsapi.fcc.gov/file/7520942052.pdf 200 https://www.ncbi.nlm.nih.gov/pubmed/21268443 
• Coburger Appeal 2005  
• Oberammergauer Appeal 2005  • Haibacher Appeal 2005  
• Pfarrkirchener Appeal 2005  
• Freienbach Appeal 2005  
• Lichtenfels Appeal 2005  
• Hofer Appeal 2005  
• Helsinki Appeal 2005  
• Parish Kirchner Appeal 2005  • Saarlander Appeal 2005  
• Stockacher Appeal 2005  
• Bamberger Appeal 2004  
• Maintaler Appeal 2004  
• Declaration of Alcalá 2002  
• Catania Resolution 2002  
• Freiburger Appeal 2002 (1000+physicians) • Salzburg Resolution 2000  
• The Stewart Report (2000) Health  Protection Agency of the UK201  
• Vienna Resolution 1998  
  
201https://webarchive.nationalarchives.gov.uk/201 00910162959/http://www.iegmp.org.uk/report/text .htm
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5. Who regulates wireless devices, cell antennas, and  the use of the Spectrum in Canada?  
In Canada, telecommunications fall under federal jurisdiction. The law that governs them  is called the Radiocommunication Act.202 
Innovation, Science and Economic Development Canada (ISED) regulates the use of  the radiofrequency spectrum, all antenna siting, and all wireless communication devices and  equipment.  
  
Among a long list of the Minister's powers, Section 5 of the Radiocommunication Act states  that "the Minister may, taking into account all matters that the Minister considers relevant for  ensuring the orderly development and efficient operation of radiocommunication in Canada,  
(i.1) issue spectrum licences in respect of the utilization of specified radio  frequencies;  
(f) approve each site on which radio apparatus, including antenna systems,  may be located, and approve the erection of all masts, towers and other  antenna-supporting structures."  
5.1. The Spectrum Auctions  
– Is the Government in a Conflict of Interest?  
Since 1999, the Canadian government has relied on auctions to allocate wireless spectrum  licences used to deliver high-speed internet services.  
The Canadian treasury makes billions of dollars from auctioning spectrum licences to  Canada's wireless network companies. According to an ISED news release (June 5, 2019),  5G wireless technologies could add up to $40 billion annually to the Canadian economy  by 2026.  
In 2019, ISED auctioned off the 600 MHz spectrum, raising $3.47 billion. In June-July  2021, the 3500 MHz band was auctioned, raising $8.91 billion on this one frequency  band.203 Canada plans to auction its extremely high frequency millimetre wave  (mmWave) spectrum that is the basis of the fastest 5G in 2024. And there is a  proposal to release the 3800 MHz spectrum in 2022. (See section 2.7 for the auction  schedule for 5G). 
Do these auctions put the Federal government in a position of conflict of interest?  
Canada’s new Digital Charter clearly favours the development of 5G, prioritizing access and  connectivity to the digital world. (from the ISED news release, June 5, 2019)  
In the above-mentioned press release, the Government of Canada announced that it is investing $199 million over five years to modernize spectrum equipment and  processes required to ensure favorable, interference-free spectrum conditions to support  world-class networks.  
This same government develops our exposure guidelines.  
  
202 https://laws-lois.justice.gc.ca/eng/acts/R-2/page-2.html#h-423843 
203 ISED. 3500 MHz auction – Process and results. July 29, 2021 https://www.canada.ca/en/innovation science-economic-development/news/2021/07/3500-mhz-auction--process-and-results.html
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5.2. Antenna Siting and Public Consultation  
– Is this Canadian democracy?  
“It made you feel like the municipalities sit at the kids' table and  
Bell and the federal government are at the adults' table.”  
-- Outgoing Mayor Joan Westland Eby (East Bolton, Québec), commenting  
on her feeling of powerlessness in trying to negotiate with the telecommunications giant and the  federal government regarding a proposed cell tower that was the object of citizen protests over two  years. The project went ahead despite objections from residents and council members.  (Brome County News, July 27, 2021) 
All companies planning to install or modify an antenna system in Canada must respect  ISED’s antenna siting procedures document, CPC-2-0-03 — Radiocommunication and  Broadcasting Antenna Systems. 
To build a new cell tower, companies must:  
∙ submit their plan to the local municipality (or land use authority) and get their  agreement in writing (letter of concurrence or equivalent);  
∙ notify residents within an area 3× the height of the proposed tower;  ∙ carry out a public consultation.  
Note: the wider community is only informed of the consultation for towers 30 metres  (98 feet) or more in height; for these tall towers only, the companies must place a  notice in a local community newspaper to inform the public of the consultation.  
This consultation:  
o is carried out by the company itself and not by an independent third party;  o health concerns are excluded, deferring to Safety Code 6;  
o the results are not made available to the public;  
o and no matter what the results are, the Minister of ISED can disregard them.  
If the Municipality does not give permission, or the citizens are strongly against the  tower, the Minister of ISED has the final say regarding whether antenna systems and  towers may be installed.  
No public consultation required for:  
∙ Existing Towers: modifications may be made, or the tower may be replaced, to  facilitate sharing or the addition of antennas, provided that the total height increase is  no greater than 25% of the height of the initial antenna system installation.  
∙ Non-Tower Structures: "antennas on buildings, water towers, lamp posts, etc. may  be excluded from consultation provided that the height above ground of the non tower structure, exclusive of appurtenances, is not increased by more than 25%."204 
Extremely high frequency emitting 5G antennas are being placed lower to the ground,  on existing telephone, street light and hydro poles and on (and in) buildings, and therefore  do not require public notification. These will begin emitting as soon as the high frequency  bands are auctioned (early 2024) – see section 2.7 for details. Existing macro towers will be  retrofitted to accommodate mid-band 5G antennas -- again without public consultation.    
204 https://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf10840.html
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5.3. Antennas must comply with environmental legislation. . . but there  are no guidelines to protect our natural environment from RF  radiation  
ISED requires that the installation and modification of antenna systems be done in a  manner that complies with environmental legislation. This includes the Canadian  Environmental Assessment Act, 2012 (CEAA 2012), recently renamed "Impact Assessment  Act", where the antenna system is incidental to a physical activity or project designated  under CEAA 2012, or is located on federal lands.  
The companies are also responsible to ensure that antenna systems are installed and  operated in a manner that respects the local environment and that complies with other  statutory requirements, as applicable, such as: Canadian Environmental Protection Act,  1999; Migratory Birds Convention Act, 1994; Species at Risk Act.  
The problem is that none of the above Acts address the effects of RF radiation used in  telecommunications.  
Not only do Canada's RF radiation exposure guidelines not protect humans effectively,  they do not even consider other mammals, birds, insects, vegetation and natural  processes.  
5.4. For health concerns, ISED defers to Health Canada’s Safety Code 6  
All antenna towers and wireless devices must comply with Health Canada's Safety Code 6  and its newly developed localized limits for 6 GHz to 300 GHz.205  
"Current exposure limits found in Safety Code 6 cover the frequency ranges that will  be used by devices and antenna installations using 5G mmWave technology."  
– ISED's Decision on Releasing Millimetre Wave Spectrum to Support 5G (SLPB-003-19, June  2019, chapter 10)  
However, Health Canada only recommends:  
 “While Safety Code 6 recommends limits for safe human exposure, Health Canada  does not regulate the general public's exposure to electromagnetic RF energy.  Industry Canada is the regulator of radiocommunication and broadcasting  installations and apparatus in Canada.”  
– Andrew Adams, Director General, Environmental and Radiation Health Sciences Directorate,  Department of Health (HESA Hearing, March 24, 2015)  
Note: There is another law governing radiation emitting devices – The Radiation Emitting  Devices Act206 and regulations207. However, they do not mention radiofrequency radiation  or telecommunications devices.  
  
205 January 2021. Notice: Localized human exposure limits for radiofrequency fields in the range of 6 GHz to  300 GHz https://www.canada.ca/en/health-canada/services/health-risks-safety/radiation/types sources/radiofrequency-fields/notice-localized-human-exposure-limits-range-6-ghz-300-ghz.html 206 Government of Canada. Radiation Emitting Devices Act: https://lois-laws.justice.gc.ca/eng/acts/R-1/ and  Radiation Emitting Devices Regulations https://lois 
laws.justice.gc.ca/eng/regulations/C.R.C.,_c._1370/FullText.html
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5.5. Does anyone monitor the RF radiation emitted by the installations?  
In ISED's siting procedures, it says that it is the responsibility of the companies to  ensure that their installations comply, including the consideration of combined effects of  nearby installations.  
How does ISED monitor installations?  
According to the Spectrum Management Operations Branch, there are two tools used by  ISED to ensure that antenna installations are compliant with Safety Code 6.  
∙ The first one is a Safety Code 6 report that ISED can request the owner of the  antenna installation to provide. It normally includes a theoretical modelling of the RF  fields around the installation to ensure that limits are respected. In the case of more  powerful transmitters, it is normally mandatory to provide such a report at the  beginning of the licence and periodically after that.  
∙ The second one is RF fields measurements done by ISED inspectors at some  chosen antenna installations each year. The purpose is to validate theoretical models  and to verify that RF fields limits from Safety Code 6 are respected. The stations that  are more powerful or that are near the Safety Code 6 limits are visited more often.  
Results of the monitoring are not normally made available to the public.  
ISED claims that it "routinely audits the radio frequency energy at tower sites".208  
However, it is not clear how it does this, since they do not seem to have much control or  knowledge about what installations exist at a given time.  
Database anomalies:  
The list of all antennas in Canada is kept in The Spectrum Licences Site Data209 and is  updated monthly.  
A C4ST volunteer has been tracking it since 2016. Since that time, we have discovered  hundreds of thousands of exact duplicate records, and hundreds of thousands of duplicate  records where the only difference between the two were the update date.  
When anomalies are pointed out to ISED's Spectrum Management Operations Branch by  C4ST's volunteer, the errors are eventually corrected. However, the Spectrum Management  Officer reminded the volunteer that:  
"The Spectrum Licence Site Data is built upon the data that spectrum licensees upload.  ISED regulates them, but the companies are responsible for updating the data."  
-- Spectrum Management Operations Branch,  
emails July 9 and Oct 24, 2019  
 
207 Government of Canada. Radiocommunication Regulations. https://laws-lois.justice.gc.ca/eng/regulations/sor 96-484/index.html 
208 https://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/h_sf11435.html 
209 http://sms-sgs.ic.gc.ca/eic/site/sms-sgs-prod.nsf/eng/h_00010.html
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Highlights:  
Date of data 
Number of  
transmitters 
Action taken 

June 1, 2020 
979,880 
On July 3, 2020, C4ST volunteer informed ISED that there were  more than 200,000 exact duplicates. On July 29, 2020, ISED  replied that they would "attempt to remove duplicate entries". 

Aug. 4, 2020 
dropped to 763,632 
Duplicate entries removed. 

Oct. 2, 2020 
jumped to 950,426 
On Oct 6, 2020, C4ST volunteer wrote to ISED:  
"The October data file now has 250,000 new entries, and no  duplicates. I don't understand what is going on. Is it possible that  250,000 new transmitters were installed in one month? Or were the  duplicates just place holders for these new transmitters? I really  would like to know who is in charge of this file. 

Nov. 2, 2020 
dropped to 773,737 
The data in the left-hand column shows wild fluctuations. We have  not been able to obtain answers for these fluctuations.  
We have asked staff at ISED's Spectrum Management  Operations Branch on numerous occasions who is ultimately  responsible for this database, and have never received an  answer to this question. 

Dec. 1, 2020 
back up to 987,215 

Feb. 1, 2021 
dropped to 785,749 

April 8, 2021 
back up to 984,873 

May 4, 2021 
dropped to 793,459 

Sept. 2, 2021 
back up to 975,254  (then changed to 873,109) 

Oct. 5, 2021 
896,505 

Nov. 2, 2021 
873,109 

Dec. 2, 2021 
major drop to  
618,477 
C4ST volunteer noticed that small cell antennas that had previously  been in the database were no longer listed. 

Jan. 25, 2022 
619,900 
On January 29, 2022, our volunteer asked ISED for an explanation  for this drop and asked if the small cell antennas were no longer to  be tracked in the database. As of February 26, 2022, no reply had  been received. 


We do not know how the "combined effects" are measured. 
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6. Surely Health Canada has safety guidelines to  protect its citizens?  
In principle yes… in reality NO.  
Sadly, this is not an area where Canada is a leader.  
 “As the former President of Microsoft Canada,  
I have witnessed the incredible benefits technology can provide.  
I also have seen the harm caused when technology is not implemented correctly.  
After extensively studying the harmful effects of wireless radiation for the last nine  years and personally meeting with over a dozen international experts,  it is clear to me that Canada’s policies  
on the use of wireless technology are not safe.  
With the imminent expansion of 5G infrastructure throughout our country,  it should be an imperative to ensure the health of Canadians is protected now  by updating Canadian standards based on the latest scientific evidence.” 
– Frank Clegg, former President of Microsoft Canada  
6.1. Safety Code 6 – Health Canada's Exposure Guidelines  
Health Canada's exposure guidelines for radiation from devices and antennas are known as  Safety Code 6 – Limits of Human Exposure to Radiofrequency Electromagnetic  Energy in the Frequency Range from 3 kHz to 300 GHz.210  
Three Types of Exposure Limits  
Safety Code 6 has three types of exposure limits for RF radiation, depending on their  distance and their operating frequency. They are calculated based on a 6-minute reference  period.  
1) Specific Absorption Rate (SAR) limits (“localized exposure” limits) – for wireless  devices used close to the body, operating at frequencies between 100 kHz and 6 GHz 
SAR is a measure of the rate at which RF energy is absorbed in the body (in a volume of  tissue), and is expressed in units of watts per kilogram (W/kg). The current SAR limit in  Canada is 1.6 W/kg (peak spatially-averaged SAR for the head, neck and trunk,  averaged over any 1 g of tissue).  
The SAR is calculated based on a mannequin.211 Scientists have protested that the  method for determining SAR is inadequate for several reasons including that the  mannequin does not represent the majority of the population and does not capture the  complex characteristics and interactions of living tissues.212,213  
  
210 https://www.canada.ca/en/health-canada/services/publications/health-risks-safety/limits-human-exposure radiofrequency-electromagnetic-energy-range-3-300.html 
211 CBC Marketplace. (2017). The Secret Inside Your Cellphone.  
https://www.cbc.ca/marketplace/m_episodes/2016-2017/the-secret-inside-your-phone 212 Environmental Health Trust. (2017). Why do scientists state that SAR is inadequate to protect cell phone  users? https://ehtrust.org/sar-test-inadequate/
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ISED requires manufacturers of wireless devices to provide information to users on the  minimum compliance distance to maintain between the product and the user.  
To find out the SAR value for your device: see your user manual or device settings or  visit ISED's Radio Equipment Search site.  
2) Field Strength Limits – for devices operating at frequencies below 10 MHz Electric and magnetic field strength limits are intended to prevent the occurrence of  nerve stimulation from devices that operate at low frequencies (below 10 MHz).  
3) Power Density limits (“whole body exposure”) – for all other devices & antennas  
Also called Whole Body Limits by Health Canada because these sources are generally  found at a distance from a person’s body, which results in the entire body being  exposed, they are currently set at 10 W/m2 for the general public. See update in green  box below.214 
Power density is the amount of electromagnetic energy in a given area, typically  expressed in watts per square metre (W/m2 or W/cm2) or as volts per square metre  (V/m2), and can be measured with an RF meter. See the Safe Living Technologies  website for a convenient conversion table.215  
UPDATE: The new 5G devices held close to the body will have many  antennas operating at frequencies below 6 GHz (must respect SAR limits)  AND above 6 GHz (must respect power density limits).  
Health Canada’s solution? Follow ICNIRP’s advice.  
Double the power density limit to 20 W/m2.
Which limit applies to which device?  
Type of wireless device 
Such as… 
Must comply with 

Devices at frequencies  
below 10 MHz 
Wireless charging devices, metal  detectors, electronic cards, tag readers  and anti-shoplifting detector panels  installed at doors of stores, etc. 
Field strength limits 

Devices used close to the  body* operating at frequencies  between 100 kHz and 6 GHz 
Cell phones, tablets and wearables 
SAR limit -- 1.6 W/kg  (peak spatially-averaged for  the head, neck and trunk,  over any 1 g of tissue)

Devices used close to the  body* at frequencies  
above 6 GHz 
Cell phones, tablets and wearables  once 5G is fully deployed
Power density limit  
(doubled to 20 W/m2 for  general public in Jan. 2021 without public consultation)

Devices used further  
from the body** 
Wi-Fi routers, baby monitors, smart  meters, home monitoring systems, etc. 
Power density limit  
(approximately 2 to 10 W/m2 for general public)

Antennas 
on cell towers and small cells (on lamp  posts, utility poles, buildings, etc.) 
Power density limit  
(approximately 2 to 10 W/m2 for general public)


* less than 20 cm / 8 inches from the body ** more than 20 cm / 8 inches from the body   
213 Clegg, F. M., Sears, M., Friesen, M., Scarato, T., Metzinger, R., Russell, C., Stadtner, A., & Miller, A. B. (June 2020).  Building science and radiofrequency radiation: What makes smart and healthy buildings, Building and Environment,  176(106324), https://doi.org/10.1016/j.buildenv.2019.106324. 214 https://www.canada.ca/en/health-canada/services/health-risks-safety/radiation/types sources/radiofrequency-fields/notice-localized-human-exposure-limits-range-6-ghz-300-ghz.html 215 Conversion tables: https://slt.co/Downloads/Education/RFConversionTable.pdf 
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∙  
6.2. Is Health Canada fulfilling its mandate?  
Health Canada’s mandate includes preventing and reducing risks to individual health and  the overall environment, and providing health information to help Canadians make informed  decisions.  
Regarding RF/EMF radiation, according to the Government’s website,216 Health Canada is  responsible for:  
∙ carrying out research into possible health effects of human exposure to  radiofrequency electromagnetic radiation from wireless devices;  
∙ monitoring the scientific literature related to such possible effects; and  ∙ developing exposure guidelines (safety limits) to protect Canadians.  
However, Health Canada:  
∙ has not carried out ANY recent research on the subject;  
∙ deliberately ignores a large number of peer-reviewed studies;  
∙ has made no major revision to its exposure guidelines since 1979 (when they  were first established) to incorporate non-heating biological effects.  
In addition, there has been no research on long-term exposures to radiation from the  new 5G technologies. We know that no such studies are being planned in the USA and  are not aware of any planned for Canada or elsewhere.  
“So there really is no research ongoing.  
We’re kind of flying blind here,  
as far as health and safety is concerned.”  
-- US Senator Richard Blumenthal  
US Senate Hearing on the Future of 5G Wireless Technology, Feb 6, 2019 
Click here to see 5 minute video of this US Senate Hearing on the Future of 5G Wireless Technology.  
  
216 First sentence in the "Background" to 2015 Revisions to Safety Code 6: Summary of Consultation  Feedback. https://www.canada.ca/en/health-canada/services/environmental-workplace health/consultations/2015-revisions-safety-code-6-summary-consultation-feedback.html 
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6.2.1. Health Canada’s guidelines for RF radiation, based on thermal effects, are  obsolete  
“Existing guidelines for RF safety only look at thermal tissue damage  
and are obsolete, since many modern studies show metabolic and genomic  damage from exposures below the level of intensity which heats tissues.”  -- American Academy of Environmental Medicine  
“I think it's irresponsible to just set standards using a thermal effect.  If you just set it based on a thermal effect, you're neglecting a large amount of data.”  – Dr. Henry Lai, Bioelectromagnetics Research Laboratory,  
Department of Bioengineering, University of Washington  
Health Canada’s exposure guidelines – Safety Code 6 – are based on a 1929 assumption  that tissue must be heated to be harmed.217,218  
This assumption was also used by ICNIRP when it developed its guidelines in 1998, and  has been nurtured ever since. ICNIRP has come under criticism for biases and conflicts of  interest. See chapter 7 – Pervasive Conflicts of Interest. 
There is substantial peer-reviewed evidence that this assumption is wrong.  It neglects the non-thermal biological effects that occur at exposure levels far lower than  those at which tissue is heated.  
Safety Code 6 has not undergone any major revisions since being established in  1979. There were only minor revisions in 1991, 1993, 1999, 2009 and 2015.  Canada’s exposure guidelines continue to be based on the “thermal argument”.  
An article published in the highly respected medical journal, The Lancet, in 2018219 questions the validity of this assumption.  
The report points to research suggesting the damage goes beyond these thermal effects  and might alter human brain metabolism, electrical activity in the brain and immune  responses. In addition, chronic exposure has been associated with increased oxidative  stress and DNA damage, and cancer risk. There also appears to be evidence for an  association between neurodevelopmental or behavioural disorders in children and exposure  to wireless devices. Prenatal exposure might cause structural and functional changes in the  brain associated with ADHD-like behaviour.  
According to the authors these findings deserve “urgent attention”. And they are not alone.  
  
217 https://www.magdahavas.com/wp-content/uploads/2010/07/Cook_1980_early_research.pdf 218 www.hc-sc.gc.ca/ewh-semt/consult/_2014/safety_code_6-code_securite_6/final_finale-eng.php See Section 2. MAXIMUM EXPOSURE LIMITS, paragraph 2 - first sentence 219 Planetary electromagnetic pollution: it is time to assess its impact - The Lancet Planetary Health, Volume 2,  Issue 12, Pe512-E514, December 1, 2018, https://doi.org/10.1016/S2542-5196(18)30221-3
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6.2.2. Safety Code 6 does not protect Canadians' health.  
Over 200 high quality peer-reviewed studies have been published showing that  radiofrequency radiation is harmful to human health below Safety Code 6 limits.220,221  
Section 3.1 of this Guide describes the long-term adverse health effects.  Section 3.2 describes the more immediate effects experienced by many Canadians.  Appendix 4 lists some of the studies showing evidence of brain cancer, impacts on children,  DNA and sperm damage, and oxidative stress which can lead to cancer, Alzheimer’s and  Parkinson’s diseases.  
Here are a few peer-reviewed studies published since the last revision of Safety Code  6 (2015), that show links to cancer, sperm damage, DNA damage, neurodegenerative  conditions and childhood development from radiofrequency (RF) radiation.222 
∙ $30 million U.S. National Toxicology Program study results223 provide “clear  evidence of cancer” and “strong evidence for the genotoxicity of cell phone radiation”  and “should put to rest the old argument that RF radiation cannot cause DNA damage” --  Ron Melnick (led the team that designed the study)224 
∙ Confirmed by the Ramazzini Institute Study225  
∙ Experts published peer-reviewed papers providing scientific evidence that  radiofrequency radiation should be reclassified as a known human carcinogen (as  are asbestos and cigarette smoking).226,227 See Section 3.1.3 for more information. 
∙ Belpomme, D., et al. Thermal and non-thermal health effects of low intensity  non-ionizing radiation228 
  
220 See: Marketplace, March 2017 – Wendy Mesley. “The Secret Inside Your Phone”. Has over 2.7 million  views. https://www.youtube.com/watch?v=Wm69ik_Qdb8 
221 200 Scientific Studies Reporting Potential Harm at Non-Thermal Levels Below Safety Code 6 Exposure  Limits http://c4st.org/?s=200+studies 
222 Smith-Roe, S. L., et al. (2019). Evaluation of the genotoxicity of cell phone radiofrequency radiation  in male and female rats and mice following subchronic exposure. Environmental and Molecular  Mutagenesis. https://doi.org/10.1002/em.22343 https://www.ncbi.nlm.nih.gov/pubmed/31633839 223 National Toxicology Program. Cell Phone Radio Frequency Radiation  
https://ntp.niehs.nih.gov/results/areas/cellphones/index.html 
224 https://microwavenews.com/news-center/ntp-comet-assay 
225 Falcioni, L., et al. (2018). Report of final results regarding brain and heart tumors in Sprague-Dawley rats  exposed from prenatal life until natural death to mobile phone radiofrequency field representative of a 1.8 GHz  GSM base station environmental emission. Environmental Research.  
https://doi.org/10.1016/j.envres.2018.01.037 
https://www.sciencedirect.com/science/article/pii/S0013935118300367?via%3Dihub 226 Miller, A. B. et al. (2018). Cancer epidemiology update, following the 2011 IARC evaluation of  radiofrequency electromagnetic fields (Monograph 102). Environmental Research, 167, 673–683.  https://doi.org/10.1016/j.envres.2018.06.043 and https://www.ncbi.nlm.nih.gov/pubmed/30196934 227 Hardell, L., & Carlberg, M. (2018). Comments on the US National Toxicology Program technical reports on  toxicology and carcinogenesis study in rats exposed to whole-body radiofrequency radiation at 900 MHz and  in mice exposed to whole-body radiofrequency radiation at 1,900 MHz. International Journal of Oncology.  https://doi.org/10.3892/ijo.2018.4606 https://www.ncbi.nlm.nih.gov/pubmed/30365129 228 Belpomme, D., et al. (2018). Thermal and non-thermal health effects of low intensity non-ionizing radiation:  An international perspective. Environmental Pollution, 242, 643–658.  
https://doi.org/10.1016/j.envpol.2018.07.019 https://www.ncbi.nlm.nih.gov/pubmed/30025338
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Hundreds of world-recognized international scientists have maintained that this type  of radiation has been proven to be harmful to humans and the environment.  
In fact, over the last 20 years, more than 40 appeals, position papers and resolutions  regarding EMF and health have been adopted by EMF researchers and physicians,  calling for more protective standards from radiofrequency radiation.  
See Chapter 4 for a list of these appeals.  
Most recently:  
∙ 255 EMF scientists from 44 nations appealed to the World Health Organization, the  United Nations Environment Programme and all member states.229  
∙ 417 scientists who focus on evaluating the scientific evidence connecting RF  radiation and harm to humans, have signed a 5G Appeal to the European Union.230 
∙ 15 organizations representing over 3500 medical doctors issued a Consensus  Statement in 2020 calling on all governments to take urgent action to protect  humans and wildlife.231 
6.2.3. Health Canada has never completed a proper review.  
Health Canada has never completed a proper systematic review of the scientific  evidence for the radiofrequencies currently used for telecommunications, i.e., a review that  meets international standards,232 nor has it published any of its analyses.  
This requires rigorous scientific methods, transparency, full public consultation from initial  scoping throughout the process, and health-protective precautionary interpretation of  findings. According to the Health Sciences Library of Columbia University:  
"Systematic Reviews are comprehensive, in-depth analyses of research  conducted on a particular question designed to inform clinical practice and policy  decisions. The review should be a planned, methodical project that aims to  uncover all relevant research via a systematic search, analysis and synthesis of  results.  
In order to adhere to a strict methodology, a protocol should be created to serve  as a plan for the review. Protocols include the research question, team members,  search strategy, databases to search, inclusion and exclusion criteria, quality  assessment tool, data extraction template, software and more. (...)  
It is best practice to create and register a protocol (...). If you create a protocol  and stick to it, your review will be of higher quality and have less risk for reporting  bias."233 
  
229 International EMF Scientists Appeal. https://www.emfscientist.org/ 
230 5G Appeal http://www.5gappeal.eu/ 
231 https://phiremedical.org/wp-content/uploads/2020/11/Press-Release-2020-Non-Ionising-Radiation Consensus-Statement-1.pdf 
232 Rooney, A. A., et al.(2014). Systematic Review and Evidence Integration for Literature-Based  Environmental Health Science Assessments. Environmental Health Perspectives.  
https://doi.org/10.1289/ehp.1307972 https://ehp.niehs.nih.gov/doi/10.1289/ehp.1307972 Abstract:  https://www.ncbi.nlm.nih.gov/pubmed/24755067 
233 https://library.cumc.columbia.edu/insight/prospero-registry-systematic-review-protocols
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If Health Canada had conducted a proper review, its protocol would be  published on the PROSPERO website.  
PROSPERO is an international database of prospective registered systematic  reviews with a health related outcome.  
https://www.crd.york.ac.uk/prospero/#aboutpage 
In fact, to the best of our knowledge, Health Canada still does not use appropriate  systematic reviewing software tools to catalogue research, extract data and compile  relevant data in order to perform proper analyses. If it did, then why do we not see this  information on Health Canada websites?  
There is one arguable exception.  
  
Recently, Health Canada stated that it did a systematic review of the literature on  studies of RF radiation at frequencies from 6 to 300 GHz in anticipation of the  widespread deployment of these higher frequencies which include millimetre  waves.  
In April 2021, it published an executive summary of its findings on its website.234 
▪ The full report was not provided. However, C4ST requested a copy and  Health Canada provided it. It is available here on the C4ST website.  
▪ Health Canada's protocol for the systematic review is not to be found in  the PROSPERO database.  
▪ Canadians were not consulted.  
  
▪ Again, only temperature was considered (as well as a pain threshold).  ▪ All tissue and cell studies were excluded.  
▪ The report states that there are no human studies that assessed the  outcomes.  
▪ The animal studies identified were all short term studies – though many of  these did find adverse effects.  
Yet, Health Canada decided it was safe to double the exposure limit to 20 W/m2 for devices used close to the body at frequencies above 6 GHz, such as cell  phones, tablets and wearables once 5G is fully deployed, i.e., using millimetre waves.  
255 world-recognized scientists have appealed to the World Health Organization and the  United Nations for standards that are more protective regarding RF radiation.  These scientists have published more than 2,000 studies on electromagnetic fields,  including RF radiation, in the peer-reviewed literature.  
Health Canada’s lack of systematic review and research capacity  —the ability to thoroughly monitor and update research syntheses—  
results in it being a laggard rather than a leader in public health. 
  
234 Analysis of recommended localized human exposure limits for radiofrequency fields in the frequency range  from 6 GHz to 300 GHz https://www.canada.ca/en/health-canada/services/health-risks-safety/radiation/types sources/radiofrequency-fields/notice-localized-human-exposure-limits-range-6-ghz-300-ghz/executive summary.html 
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6.2.4. Health Canada's decisions are not based on all of the current scientific  evidence.  
When new information becomes available, the proper scientific approach is to study and  analyze the results to ensure a current premise is still correct. Health Canada appears to  do the opposite and look for ways to dismiss any new evidence that challenges its  assumptions.  
For example,  
∙ In its last review of Safety Code 6 (2015), rather than embracing new scientific  evidence as is the proper practice, Health Canada disregarded studies that did not  conform to its 1929 assumption that tissue must be heated to be harmed.235 
∙ Health Canada shows complete disregard for the $30 million US National  Toxicology Program study involving over 3,000 rodents over 10 years that provided  clear evidence of cancer and DNA damage—despite the fact that this study passed  through peer-review three times before publication. Health Canada’s statement “The  RF exposure levels tested in the study were 19 to 75 times higher than the human  exposure limits established internationally and within Canada for whole body exposure  for humans” has been refuted by Dr. Ron Melnick in a Jan. 4, 2018 email to The  Honourable Ginette Petitpas Taylor, Minister of Health. Dr. Melnick was the lead  scientist for the design of the NTP study and was also a member of the WHO’s IARC  panel in 2011 that classified RF EMF as possibly carcinogenic to humans.  
∙ 255 world-recognized scientists from 44 nations have appealed to the World Health  Organization and the United Nations for more protective standards from RF  radiation.236 There is also a 5G Appeal by scientists who focus on evaluating the  scientific evidence connecting RF radiation and harm to humans. 237 
6.2.5. Health Canada relies on biased organizations when setting its  exposure guidelines.  
Health Canada relies on the following organizations when establishing its guidelines:  
∙ World Health Organization’s International EMF-Project (WHO-EMF Project)  
The WHO states that “there are no adverse short- or long-term health effects" from  exposure to wireless networks,238 completely disregarding its own International  Agency for Research on Cancer (IARC) which in 2011 classified RF radiation as a  possible human carcinogen (Group 2B – same category as lead and DDT at the  time). In fact, in 2019, IARC decided that: "based on new evidence, non-ionizing  radiation (radiofrequency) should be a high priority for re-evaluation of the  classification" (Report of the Advisory Group to Recommend Priorities for the IARC  Monographs during 2020–2024)239 
  
235 www.hc-sc.gc.ca/ewh-semt/consult/_2014/safety_code_6-code_securite_6/final_finale-eng.php See Section 2. MAXIMUM EXPOSURE LIMITS, paragraph 2 - first sentence 
236 International EMF Scientists Appeal. https://www.emfscientist.org/ 
237 5G Appeal http://www.5gappeal.eu/ 
238 https://www.who.int/teams/environment-climate-change-and-health/radiation-and-health/bstations wirelesstech 
239 https://monographs.iarc.fr/wp-content/uploads/2019/10/IARCMonographs-AGReport-Priorities_2020- 2024.pdf
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The WHO-EMF Project is “industry-friendly” and heavily influenced by the International  Commission for Non-Ionizing Radiation Protection (ICNIRP) when making its  recommendations.  
∙ International Commission for Non-Ionizing Radiation Protection (ICNIRP)  
ICNIRP is a private self-appointed non-governmental group, consisting mainly of  engineers with ties to the telecommunications industry and the US military.240  
Its exposure limit  
guidelines influence  
many countries,  
including Canada.  
Its power density limits  
are based on the 1929  
assumption that tissue  
must be heated to be  
harmed. See section  
6.2.1 for more on this  
obsolete assumption.  
40% of the world’s  
population has  
exposure limits at least  
10-fold lower than  
ICNIRP’s.  
Source: Dr. Isaac Jamieson241 
∙ the IEEE (formerly known as Institute of Electrical and Electronics Engineers)  IEEE is the world's most powerful federation of engineers. The members are or have  been employed in companies or organizations that are producers or users of  technologies that depend on radiation frequencies, such as power companies, the  telecom and the military industry. IEEE has prioritized international lobbying efforts for  decades especially aimed at the WHO.  
∙ the United States  
In a report published by Harvard University Press Captured Agency - How the Federal  Communications Commission Is Dominated by the Industries It Presumably Regulates,  Norm Alster outlines how the inordinate influence of corporate interests led to errors of  commission and omission at the FCC.  
These organizations have come under criticism for biases and conflicts of  interest.242,243,244,245,246 
See Chapter 7 "Pervasive Conflicts of Interest" for more on the WHO and ICNIRP.  
  
240 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5504984/ 
241 RF/Microwave Radiation and Risk Awareness • EMF: AV_RM0140721  
https://www.eesc.europa.eu/resources/docs/emf_report_-provided-by-dr-jamieson.pdf 242 https://www.spandidos-publications.com/10.3892/ijo.2017.4046 
243 https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2902287 
244 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5504984/ 
245 https://www.ncbi.nlm.nih.gov/pubmed/26688202 
246 https://www.ncbi.nlm.nih.gov/pubmed/27902455
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In December 2020, the Washington Spectator published a major exposé by investigative  journalist Barbara Koeppel on industry influence into the science and policy of 5G  and wireless radiation. She details industry ties between the ICNIRP, the Food and Drug  Administration, The Center for Disease Control and Prevention, The New York Times, the  American Cancer Society, and scientists professing that 5G is safe.247  
Now that there are close to 2,000 studies showing serious biological effects (such as  cancer) at levels far lower than what ICNIRP deems safe, and hundreds of these are of  very high quality, many are wondering why ICNIRP and the WHO continue to ignore  these studies.  
Why is Health Canada relying on others instead of doing its own homework?  
BREAKING NEWS: TWO WRONGS DO NOT MAKE A RIGHT:  
US Court states that the FCC cannot rely on other agencies like the FDA  if the FDA’s conclusions are provided without explanation.  
On August 13, 2021, the United States Court of Appeals for the District of Columbia  Circuit ordered the FCC to explain why it ignored scientific evidence showing  harm from wireless radiation, stating that the decision by the FCC to retain its 1996  safety limits for human exposure to wireless radiation was “arbitrary and capricious.”  
The FCC, when justifying its safety limits, points to the Food and Drug Administration  (FDA) who do not provide any explanation as to why they persist in retaining their  1996 limits, ignoring the scientific evidence that shows harm.  
In response to this, the US Court of Appeals wrote that the commission cannot rely on  agencies like the Food and Drug Administration (FDA) if the FDA’s conclusions are  provided without explanation.  
"While imitation may be the highest form of flattery, it does not meet even the low  threshold of reasoned analysis required by the APA under the deferential standard  of review that governs here. One agency’s unexplained adoption of an unreasoned  analysis just compounds rather than vitiates the analytical void. Said another way,  two wrongs do not make a right," the court wrote.  
The same is happening here in Canada.  
ISED defers to Health Canada which does not provide a full justification for excluding  evidence for non-thermal effects when setting its limits and instead refers to the  WHO-EMF Project and ICNIRP, which also do not provide full justifications for  exclusion.  
For more information on this historic ruling, see section 10.2.
Whatever the reason, Health Canada continues to mislead Canadians, stating that  there is currently no published evidence showing a link to adverse health effects at the  levels permitted by Safety Code 6, including exposure from equipment that uses 5G  technology, despite ample evidence to the contrary.248  
  
247 The Washington Spectator. (2020). Wireless Hazards. https://washingtonspectator.org/wireless-hazards/ 248 https://www.canada.ca/en/health-canada/services/health-risks-safety/radiation/occupational-exposure regulations/safety-code-6-radiofrequency-exposure-guidelines.html#How_Safety_Code_2 
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6.2.6. Health Canada's process to update Safety Code 6 is deeply flawed.  
For the most recent review of Safety Code 6 – in 2015 – Health Canada contracted with the  Royal Society of Canada (RSC). The RSC convened a panel of eight experts to evaluate  the research and produce a report on Safety Code 6. Their report was released in 2014.  
A few months later, the Canadian Medical Association Journal (CMAJ) reported  concerns that were raised by two respected scientists who had been invited to peer-review  the Report.249  
In an interview with the CMAJ, Dr. Anthony Miller suggested that instead of outsourcing the  safety review to an organization that is not subject to government accountability and  transparency rules, Health Canada should conduct the safety review internally, using  traditional expert advisory panel review procedures, which are more accountable.  
Panel Riddled with Conflicts of Interest and Lack of Expertise  
“The panel included members with major links to the telecommunications  industry. This is a conflicted panel, with insufficient expertise in epidemiology.  It ignored recent evidence that wireless radiation is a probable carcinogen."  
− Dr. Anthony B. Miller, professor emeritus, University of Toronto's Dalla Lana  
School of Public Health and Medal of Honour recipient from the World Health  
Organization’s International Agency for Research on Cancer,  
The peer-reviewers flagged their concerns about major conflicts of interest as well as lack of  expertise within the eight-member panel. The chair had an undisclosed conflict of interest  and was replaced. And two other members stepped down... While a fourth with suspected  links to the telecommunications industry remained on the panel. Finally, one of the vacant  seats was filled by an ICNIRP member. According to the peer-reviewers, these changes  were unsatisfactory.  
Vital Evidence Omitted250 
“The RSC's eight-member panel actively blinded themselves to vital evidence.  The panel’s position on maintaining the current standards is so fixed that it  leads them to conclusions one would never expect from policy officials in the  field of health.  
I am almost certain that the reluctance of the panel to be guided by biological  evidence reflects a lack of expertise in cell biology”  
− Dr. Martin Blank, expert on the effects of electromagnetic radiation and  
special lecturer at the Columbia University Medical Center, New York (now deceased)  
  
249 Webster, P. C. (2014). Federal Wi-Fi safety report is deeply flawed, say experts. CMAJ: Canadian Medical  Association Journal, 186(9), E300. https://doi.org/10.1503/cmaj.109-4785 
250 Canadian scientists urge more research into safety of wireless technology, saying recent report  downgrades cancer risk. The National Post. April 15, 2014. https://nationalpost.com/health/canadian scientists-urge-more-research-into-safety-of-wireless-technology-saying-recent-report-downgrades-cancer-risk
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When Safety Code 6 was being revised in 2014 . . .  
∙ Health Canada ignored 140 peer-reviewed studies showing harm at levels at, or  below Safety Code 6  
As part of a public consultation in 2014 regarding the review of Safety Code 6,  Canadians for Safe Technology (C4ST) submitted to Health Canada a list of 140  peer-reviewed studies showing harm at levels at, or below Safety Code 6, that the  Royal Society’s panel omitted in its review.251 
Health Canada ignored all of this evidence-based information when setting  Safety Code 6 limits although it did admit that 36 of the studies met its criteria as  being “in scope” for risk assessment, and were considered in their weight-of-evidence  analysis. Twenty-six were at or below Safety Code 6 limits. (See Appendix 7 for the  list of studies that Health Canada deemed were “in scope for risk assessment”, and  its two-page analysis which does not explain why they were rejected).  
No weight-of-evidence analysis was provided. When inquiries were made about  the reasons for excluding this evidence, Health Canada provided an unpublished  discussion paper “Safety Code 6 (2015) – Rationale”252 that has no rationale for  excluding these and other non-thermal studies. Instead it cites other authorities. Bias  and conflict of interest of some of these authorities has been outlined in a number of  papers.253 See chapter 7 for more information on these biased organizations.  
∙ Health Canada ignored requests in 2014 by over 100 Canadian medical  doctors254 and international scientists255 to set more protective safety guidelines.  The scientists signed Declarations urgently calling on Health Canada to:  
o intervene in what they view as an emerging public health crisis;  o establish guidelines based on the best available scientific data; and  o advise Canadians to limit their exposure and especially the exposure of  children.  
They said that “Canada’s Safety Code 6 Guideline is fundamentally flawed.”  
“It is based on an obsolete account and analysis of the research  
and has disregarded or minimized certain recent studies,  
such as cancer, DNA damage, protein synthesis, stress response,  
and detrimental biological and health effects in humans that occur  
at RFR intensities below the existing Code 6 Guideline.”  
  
251 Canadians for Safe Technology. (2014). Relevant scientific studies (140) omitted by Health Canada in its  scientific review of draft Safety Code 6 (2014), Canada’s safety guidelines for safe exposure to  radiofrequency/microwave radiation. Submission to the Federal Minister of Health Canada, Honourable Rona  Ambrose 15 July 2014, 213 pages. docs.c4st.org/Studies/140_studies_omitted_by_Health_Canada.pdf 252 Health Canada. (2015). Safety Code 6 (2015) – Rationale. Unpublished Discussion Paper, 62 pages.  docs.c4st.org/GovRelations/Fed/Health-Canada/Health-Canada-Safety-Code-6-2015-Rationale_62- pages_Unpublished-discussion-paper.pdf 
253 Clegg et al. 2019 https://www.sciencedirect.com/science/article/pii/S0360132319305347 254 Declaration: Doctors Call for Protection from Radiofrequency Radiation Exposure. (2014, September 28).  Retrieved July 13, 2014. http://www.c4st.org/images/documents/hc-resolutions/medical-doctors-submission-to health-canada-english.pdf 
255 Declaration: Scientists call for Protection from Radiofrequency Radiation Exposure. (2014, July 9).  Retrieved July 13, 2014. http://www.c4st.org/images/documents/hc-resolutions/scientific-declaration-to-health canada-english.pdf
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6.2.7. Health Canada's guidelines are behind other countries  
While it may be true that many countries follow ICNIRP and base their guidelines only on  the thermal effects of RF radiation, there are many countries, states, and cities around the  world that are doing a lot more to protect their citizens.  
Canada should be among them.  
∙ China, Russia, Italy, Switzerland, India, Israel, Chile, Poland, Lithuania, Slovenia, and  parts of Belgium, have power density guidelines that are between 5 and 100 times  safer than Canada’s.  
∙ Parts of Italy, Switzerland, Ireland and the UK, have put a halt to the rollout of 5G  until more is known about possible adverse effects.256  
∙ France adopted a comprehensive law in 2015 that protects the public from  excessive exposure to RF radiation.257  
Among its articles:  
o Wi-Fi is banned in nurseries for children under the age of 3;  
o Wi-Fi in primary schools (under age 11) is enabled only when used for lessons.  o Signage is required to inform the public when Wi-Fi is offered in a public place.  o At the point of sale of mobile phones, the SAR value must be clearly shown.  
o In the future, all mobile phone advertisements must include recommendations on  how users can reduce RF radiation exposure to the head such as the use of  headsets.  
o Data on local EMF exposure levels shall be made more easily accessible to the  general public, among others, through country-wide transmitter maps.  
See Chapter 10 for more on what others are doing to protect their citizens and themselves.  
  
256 Environmental Health Trust. International Actions to Halt 5G. https://ehtrust.org/international-actions-to-halt and-delay-5g/  
257 https://www.legifrance.gouv.fr/loda/id/JORFTEXT000030212642/
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Canada’s RF Exposure Guidelines Compared to Others 
Intensity (mW/m2)

CANADA


– for devices used close to the body (6 GHz to 300 GHz),        i.e., cell phones, tablets and wearables once 5G is fully deployed 258 
                   20,000

– for 6 GHz to 150 GHz  * 
                   10,000

– for 5 GHz  Wi‐Fi networks **** 
8,830

– for 2.4 GHz  Wi‐Fi networks and cordless phones  **** 
5,350

– for 2.1 GHz  LTE cellular networks   **** 
                   4,880

– for 900 MHz – for example wireless "smart" meters   **** 
                   2,740

COMPARED TO. . .


Russia, Slovenia (2100 MHz) †   
1,000

Israel, India, Lithuania (1800 MHz) † 
900

Brussels Capital Region †† 
560

Israel, India, Lithuania (900 MHz) † 
450

Slovenia (900 MHz) † 
450

China  † 
400

Italy † near homes, schools, places where people stay more than 4 hours 
100

Poland  † 
100

Chile  † near schools, kindergartens, hospitals, care homes 
100

Switzerland (1800 MHz), Lichtenstein, Luxembourg *** 
95.5

Switzerland (900 MHz) *** 
42.5

Belgium's Wallonia and Flanders **** 
24

Austrian Antenna System Siting Guideline (2012, updated 2015) **** 
1

Parliamentary Assembly of Council of Europe **** 
1

EUROPAEM (MDs) ‐ daytime** 
0.1

EUROPAEM (MDs) ‐ nightime** 
0.01

BioInitiative 2012259   
0.006

EUROPAEM (MDs) ‐ sensitive populations** 
0.001

Natural background level (all RF frequencies)***   
0.000000001

Cosmic background *** 
0.00000000000001


SOURCES: * Safety Code 6;  **  Belyaev, et al. (2016). European Academy for Environmental Medicine (EUROPAEM)  EMF Guideline 2016 for the prevention, diagnosis and treatment of EMF-related health problems and illnesses.  Reviews on Environmental Health, 31(3). https://doi.org/10.1515/reveh-2016-0011;  
*** https://www.powerwatch.org.uk/science/intguidance.asp; **** KatharinaConsulting.com (2018) † WHO https://www.who.int/data/gho/data/themes/topics/indicator-groups/indicator-group-details/GHO/exposure-limits for-radio-frequency-fields-(public) - updated 2017 
 † † July 2021: Brussels increased their limit by a factor of 5: https://stop5g.be/fr/lettre/CP/20210901.htm#_edn1   
258 Health Canada (Jan 2021). Notice: Localized human exposure limits for radiofrequency fields in the range  of 6 GHz to 300 GHz https://www.canada.ca/en/health-canada/services/health-risks-safety/radiation/types sources/radiofrequency-fields/notice-localized-human-exposure-limits-range-6-ghz-300-ghz.html 259 BioInitiative Working Group, Sage C, Carpenter DO, editors. BioInitiative Report: A Rationale for a  Biologically-based Public Exposure Standard for Electromagnetic Radiation at www.bioinitiative.org,  December 31, 2012. 
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6.3. Report of the House of Commons Standing Committee on Health  (HESA) Ignored  
In 2015, the House of Commons Standing Committee on Health (HESA) held hearings that  included invited testimony and briefs from Canadian and international experts.  
Its report entitled “Radiofrequency Electromagnetic Radiation and the Health of  Canadians” which included 12 recommendations,260 concluded that:  
 “the potential risks of exposure to RF fields are a serious public health issue   that needs to be brought to the attention of Canadians”. 
THE 12 RECOMMENDATIONS*  
https://www.ourcommons.ca/Content/Committee/412/HESA/Reports/RP8041315/hesarp13/hesarp13‐e.pdf 
1. That the Government of Canada, in collaboration with the health departments of the provinces and territories, examine existing cancer data collection methods to improve the collection of information relating to wireless device use and cancer. 
2. That Statistics Canada consider including questions related to electromagnetic hypersensitivity in the Canadian Community Health Survey. 
3. That the Government of Canada, through the Canadian Institutes of Health Research, consider funding research into electromagnetic hypersensitivity testing, diagnosis and treatment, and its possible impacts on health in the workplace. 
4. That the Canadian Medical Association, the Royal College of Physicians and Surgeons, the College of Family Physicians of Canada and the World Health Organization consider updating their guidelines and continuing education materials regarding the diagnosis and treatment of electromagnetic hypersensitivity to ensure they are based on the latest scientific evidence and reflect the symptoms of affected Canadians. 
5. That the Government of Canada continue to provide reasonable accommodations for environmental sensitivities, including electromagnetic hypersensitivity, as required under the Canadian Human Rights Act. 
6. That Health Canada ensure the openness and transparency of its processes for the review of Safety Code 6, so that all Canadians have an opportunity to be informed about the evidence considered or excluded in such reviews, that outside experts are provided full information when doing independent reviews, and that the scientific rationale for any change is clearly communicated. 
7. That the Government of Canada establish a system for Canadians to report potential adverse reactions to radiofrequency fields. 
8. That an independent scientific body recognized by Health Canada examine whether measures taken and guidelines provided in other countries, such as France and Israel, to limit the exposure of vulnerable populations, including infants, and young children in the school environment, to radiofrequencies should be adopted in Canada. 
9. That the Government of Canada develop an awareness campaign relating to the safe use of wireless technologies, such as cell phones and Wi‐Fi, in key environments such as the school and home to ensure that Canadian families and children are reducing risks related to radiofrequency exposure. 
10. That Health Canada conduct a comprehensive review of all existing literature relating to radiofrequency fields and carcinogenicity based on international best practices.


  
260 https://www.ourcommons.ca/DocumentViewer/en/41-2/HESA/report-13/ 
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11. That the Government of Canada, through the Canadian Institutes of Health Research, consider funding research into the link between radiofrequency fields and potential health effects such as cancer, genetic damage, infertility, impairment to development and behaviour, harmful effects to eyes and on the brain, cardiovascular, biological and biochemical effects. 
12. That the Government of Canada and manufacturers consider policy measures regarding the marketing of radiation emitting devices to children under the age of 14, in order to ensure they are aware of the health risks and how they can be avoided.


* [Bolding added for scannability]   
What happened to this Report?  
∙ June 17, 2015: presented to the House of Commons (Conservative Government)  o Shelved because of the Federal election in October 2015.  
∙ June 15, 2016: re-adopted after the election by the new HESA Committee, and  presented once again to the House of Commons. (Liberal Government)  
o No action was taken. Response from The Honourable Jane Philpott,  Minister of Health at the time, dismissed the committee’s recommendations.261  In her response, she stated that “Health Canada uses a “weight of evidence”  approach in evaluating scientific studies”. Despite numerous requests, and in  contrast to standard scientific procedure, Health Canada has never published  its weight of evidence criteria or analyses.  
6.4. Why is Health Canada not acting?  
6.4.1. Not one of the recommendations made by the House of Commons Standing  Committee on Health (HESA) in 2015 has been fully implemented.  
Despite the HESA Committee's conclusion that “the potential risks of exposure to RF fields  are a serious public health issue that needs to be brought to the attention of  Canadians” and its 12 recommendations made to the House of Commons in 2015, and  despite it being re-adopted and presented for a second time – this time to the 42nd Parliament (Liberal Government) in 2016, this Report (see previous section) has fallen on  deaf ears.  
C4ST replied to then Health Minister Jane Philpott’s dismissive response in 2016, outlining  concerns that Health Canada was not protecting Canadians262 by:  
∙ Neglecting to run awareness campaigns to inform Canadians on how to use their  wireless devices more safely;  
∙ Allowing the wireless industry to bury their safety warnings in their manuals;  ∙ Misrepresenting Canada’s safety guidelines compared to other countries;  
∙ Refusing to invest the resources to understand electromagnetic hypersensitivity  (EHS) better. It is estimated that at least 3% of the population suffers from EHS.  
∙ Failing to meet the international scientific standards for systematic literature review;  
∙ Dismissing the large body of credible evidence that there are harmful biological  effects below Safety Code 6 limits.  
  
261 https://www.ourcommons.ca/DocumentViewer/en/42-1/HESA/report-2/response-8512-421-78 262 http://c4st.org/minister-health-response-hesa-recommendations/
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6.4.2. How much more evidence does Health Canada need?  
∙ Well over 200 peer-reviewed studies have been published since the last revision  of Safety Code 6 (2015), showing that radiofrequency radiation has potentially  harmful biological effects below Safety Code 6 limits.263,264  
See Appendix 4 for a few of the studies showing evidence of brain cancer, impact on  children, DNA and sperm damage, and oxidative stress which can lead to cancer,  Alzheimer’s and Parkinson’s diseases.  
∙ At a 2019 symposium hosted by the Environmental Health Clinic, Women’s College  Hospital in Toronto, Canadian scientists and physicians publicly stated that full 5G  rollout will expose Canadians to an unprecedented increase in radiofrequency  radiation.265 They expressed concern that our health care costs will rise without our  medical professionals understanding why, and not having the necessary information  for making adjustments accordingly.266 
∙ Physician accrediting bodies are accrediting medical conferences.  The accrediting bodies that offer Continuing Medical Education (CME) have approved  conferences on this topic aimed at educating family physicians and specialists. For  example:  
All-Day Symposium for Ontario’s medical community: Impacts of Wireless  Technology on Health – May 31st, 2019267 
Hosted by Environmental Health Clinic, Women’s College Hospital, Toronto  
Approved by the CPD Department of the Faculty of Medicine, University of Toronto, for:  6 MOC Section 1 Credits (Royal College of Physicians and Surgeons of Canada)  6 Mainpro+ and CERT+ credits (College of Family Physicians of Canada)  
EMF Medical Conference – January 28-31, 2021 – 600 attendees  
4-day virtual conference organized jointly by US-based CME provider AKH Inc.,  Advancing Knowledge in Healthcare and The Electromagnetic Safety Alliance, Inc.  
Approved for 20.5 AMA PRA Category 1 Credits  
Through an agreement between the Royal College of Physicians and Surgeons of Canada and the American  Medical Association, physicians may convert AMA PRA Category 1 Credits™ to Royal College MOC credits.  
  
263 See: Marketplace, March 2017 – Wendy Mesley. “The Secret Inside Your Phone”. Has over 2.7 million  views. https://www.youtube.com/watch?v=Wm69ik_Qdb8 
264 200 Scientific Studies Reporting Potential Harm at Non-Thermal Levels Below Safety Code 6 Exposure  Limits http://c4st.org/?s=200+studies 
265 Impacts of Wireless Technology on Health: A symposium for Ontario’s medical community.  https://www.womenscollegehospital.ca/care-programs/environmental-health-clinic/june-2019-conference videos 
266 Media Release - Ontario Doctors Warn of Rising Health Care Costs after 5G Roll Out  https://www.youtube.com/watch?time_continue=4&v=S16QI6-w9I8 
267 https://www.womenscollegehospital.ca/care-programs/environmental-health-clinic/electromagnetic-field hypersensitivity-(ehs)
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6.4.3. Health Canada’s track record has been poor in responding to other harmful  agents.  
Health Canada has a dismal track record in responding in a timely manner to harmful  agents. Think asbestos, Bisphenol-A (BPA), cigarette smoking, dioxins, flame retardants,  lead, mercury, thalidomide and urea formaldehyde insulation.  
Here are a few examples.  
∙ Cigarettes were causing cancer; studies proved it; our government waited another  40 years before passing legislation to require warning labels on packages.268 
∙ Since the early 1900s, health authorities have known that asbestos causes  mesothelioma, a deadly form of lung cancer.  
o By 2005 it was banned throughout the European Union.  
o Canada waited another 14 years to ban it (until 2019 -- 100 years after it  discovered the serious health risk it posed).  
o Canada has one of the highest rates of mesothelioma in the world.  o Asbestos-related deaths are on the rise because of the latency period (it takes  years to die from asbestos).  
∙ Glyphosate (a dangerous pesticide) is still allowed in Canada, while 21 countries in  the rest of the world are banning or restricting it.269,270 In fact, Health Canada is  considering loosening restrictions.271 
∙ Regarding BPA, Health Canada’s website states: “Health Canada's Food Directorate  has concluded that the current dietary exposure to BPA through food packaging uses  is not expected to pose a health risk to the general population including newborns and  infants”.272 
∙ In 1959, the Government of Canada allowed samples of thalidomide to be distributed  to patients by "qualified investigators", and on April 1, 1961, it officially authorized  distribution of thalidomide in Canada. At the time, the US Food and Drug  Administration had refused to approve it because of a lack of sufficient research.  On March 2, 1962, Canadian authorities finally withdrew the drug from the market (a  full three months after it was taken off the market in its own country of origin) after several doctors brought up concerns that it appeared to be responsible for severe  birth defects when taken by pregnant women.273 It took over 50 years for the  Government of Canada to launch a proper financial compensation program for  survivors.274 To this day, the Government of Canada has never formally acknowledged  its share of responsibility for this tragedy.  
The wireless industry is growing rapidly. Our government is not keeping up.  For the past 20 years, Health Canada has refused to consider the large body of evidence  that proves that RF radiation has harmful effects at levels far below Safety Code 6.  
  
268 http://www.smoke-free.ca/pdf_1/2009/History%20of%20tobacco%20control%20in%20Canada.pdf 269 https://www.canada.ca/en/health-canada/news/2019/01/statement-from-health-canada-on-glyphosate.html 270 https://sustainablepulse.com/2019/05/28/glyphosate-herbicides-now-banned-or-restricted-in-17-countries worldwide-sustainable-pulse-research/#.X3Teoj-Slpg 
271 https://montreal.ctvnews.ca/higher-concentrations-of-controversial-herbicide-glyphosate-may-soon-be-on your-plate-here-s-why-1.5515198 
272 https://www.canada.ca/en/health-canada/services/food-nutrition/food-safety/packaging materials/bisphenol.html 
273 https://thalidomide.ca/en/the-canadian-tragedy/ 
274 https://www.canada.ca/en/health-canada/services/thalidomide-survivors-contribution-program.html

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