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Canadian experts and citizens’ groups object to release of mmWave spectrum and call for a moratorium on 5G expansion

Joint Statement to Innovation, Science and Economic Development Canada (ISED)

In response to: Consultation on a Policy and Licensing Framework for Spectrum in the 26, 28 and 38 GHz Bands

Reference: Canada Gazette, Part I, Volume 156, Number 25, June 18, 2022, Notice No. SPB-001-22:
Consultation on a Policy and Licensing Framework for Spectrum in the 26, 28 and 38 GHz Bands


Most Canadians are presently exposed to “wireless” radiation (radiofrequency electromagnetic radiation, RF-EMR) levels a quintillion times higher than the natural background.  Experts warn that this poses a serious risk to our health and to the environment.  In operation, millimetre waves would be emitted by antennas installed on cell towers and by hundreds of thousands of complex “small cells” across Canada (e.g. on/in buildings, utility poles and other structures); many in very close proximity to people and wildlife.  In addition, millions of wireless devices such as cell phones would further contribute to exposures.

Support this Statement

Experts and groups are invited to support the Joint Statement. Please contact:

All Canadians may submit comments to ISED.


WE, Canadian Experts and Citizens’ Groups, urgently call for a MORATORIUM on the release of the extremely high frequency millimetre wave spectrum (mmWaves)

including the 26/28 and 38 GHz bands


Innovation, Science and Economic Development Canada (ISED), Health Canada, and Environment and Climate Change Canada (ECCC) complete the following:

  1. Comprehensive studies, with hazard and risk analyses of known and potential adverse health effects (human and environmental), including non-thermal biological effects, of exposures to radiofrequency electromagnetic radiation (RF-EMR). This includes millimetre waves. [1]
  2. Health Canada develops demonstrably safe exposure limits for RF-EMR, to incorporate the non-thermal effects, basing limits on a health-protective precautionary interpretation of the findings (i.e., a reasonable certainty of “no harm,” especially for pregnant women, children, the elderly, people who are ill, and people who are electrosensitive).
  3. ECCC establishes legally binding exposure limits to protect the environment, including wildlife all flora and fauna — against harm from RF-EMR.
  4. ISED establishes procedures that are fully transparent and effective to:
    • monitor and report RF-EMR emissions, as measured from existing equipment and modelled for proposals;
    • map environmental exposure levels (existing and proposed) for all areas across Canada;
    • ensure industry compliance with more stringent regulatory requirements for infrastructure and devices;
    • ensure that no frequency bands are released that could place lives at risk by interfering with critical Earth observation data (e.g., that would reduce weather forecasting accuracy);
  5. ISED establishes a meaningful, comprehensive and transparent process for municipalities and citizens to have a decisive say over whether and where cellular network antennas are installed, on both towers and non-tower structures (e.g., lamp posts, hydro poles and buildings). [2]

[1] This study by a truly independent panel with appropriate expertise, requires rigorous scientific methods, transparency, full public consultation from initial scoping throughout the process, and health-protective precautionary interpretation of findings.

[2]  Informed public participatory consultation and local decision-making, giving full consideration of environmental, health and security issues, and of hazards, risks and costs of wireless expansion compared to alternatives (e.g., use of fibre/cable), must replace the broad powers currently vested in the Minister of ISED.

Joint Statement Signatories (August 26th):

Prevent Cancer Now
Canadians for Safe Technology
Friends of the Earth Canada
Electromagnetic Pollution Illnesses Canada Foundation
Canadian Educators for Safe Technology
Environmental Health Association of Manitoba
Rassemblement ÉlectroSensibilité Québec
Manitobans for Safe Technology
Association québécoise de lutte contre la pollution atmosphérique (AQLPA)
CALM (Call to Action to Limit Microcells)
Stoppons la 5G
Vivons sans danG
Well Earth Collaborative
Albertans for Safe Technology
Citizens for Safer Tech
Electrosensitive Society
Safe Living Technologies
Citizens Against the Proliferation of Cell Antennas in the Eastern Townships
Expert Signatories

Jennifer M. Armstrong, MD
Ottawa Environmental Health Clinic Ottawa, Ontario

Riina Bray, BASc, MSc, MD, FCFP, MHSc
Medical Director, Environmental Health
Clinic, Women’s College Hospital; Assistant Professor, Department of Family and Community Medicine, University of Toronto
Toronto, Ontario

Jean‐Paul Dorst, PhD (Biophysics)
Winkler, Manitoba

Marg Friesen, BSc (Honours, Zoology), MSc (Entomology/ Toxicology)
Retired research scientist (Government of Canada and Manitoba);
Environmental Health Association of Manitoba, Canadians for Safe Technology,
Winnipeg, Manitoba

Pascal Gélinas
Documentariste, Membre émérite de L’ARRQ (Association des Réalisateurs et Réalisatrices du Québec)
Réalisateur aux émissions « Science‐Réalité » et « Découverte » (Ici Radio‐Canada télé) de 1984 à 2009
Montréal, Québec

Magda Havas, BSc, PhD
Professor Emerita, Trent University
Peterborough, Ontario

Paul Héroux, BSc, MSc, PhD
Professor of Toxicology and Health Effects of Electromagnetism, McGill University Medicine Department of Surgery, McGill University Health Centre (MUHC),
Montreal, Québec

David Fancy, PhD
Disability Advocate, Full Professor, Brock University
Hamilton, Ontario

Paul LeMay, BA (Psych), Dipl. S.A.
Science writer and author specializing in human behaviour and brain science
Vancouver, British Columbia

Barry Malowanchuk, P.Eng.
Telecommunications Engineer, Manitoba Hydro (retired, 37 years service) responsible for RF Radiation Safety compliance according to Safety Code 6 guideline;
20+ years Maintenance Engineer for microwave and mobile radio,
Winnipeg, Manitoba

David S. McRobert, BSc, MES, LLB
Former Senior Counsel, Environmental Commissioner of Ontario
Peterborough, Ontario

Anthony B Miller, MD, FRCP, FRCP (C), CM
Cancer Epidemiologist
Professor Emeritus, Dalla Lana School of Public Health, University of Toronto
Toronto, Ontario

Rob Metzinger
Electronics Engineering Technologist
Building Biology Environmental Consultant BBEC, Electromagnetic Radiation Specialist EMRS, and Senior EMR Instructor, Building Biology Institute (Santa FE, NM),
Guelph, Ontario

Meg Sears, MASc, PhD
Environmental health scientist
Ottawa Hospital Research Institute, Prevent Cancer Now,
Ottawa, Ontario

Kate B. Showers, BA, BS, MS, PhD
Senior Research Fellow, Department of Geography and Centre for World Environmental History,
University of Sussex (England)
Sutton, Québec

Colin L. Soskolne, BSc, BSc Hons, PhD
Professor emeritus (Epidemiology), University of Alberta,
Montréal, Québec

Nick Wallace
President, QSR Electrical Engineering
Sarnia, Ontario

Consultation deadline: September 6, 2022. Reply comments deadline: November 8 2022
Please send your comments in a Word document or PDF format, by email to:
IMPORTANT DETAILS you must include:
Reference: Canada Gazette, Part I, Volume 156, Number 25, June 18, 2022, Notice No. SPB-001-22:
Consultation on a Policy and Licensing Framework for Spectrum in the 26, 28 and 38 GHz Bands

Send an attachment – do not simply include comments in the body of the email.

Download a PDF of Joint Statement, plus Six Reasons for a Moratorium


Six Reasons for a moratorium on the release of the millimetre wave spectrum (mmWaves)

What was the result of the 2017 consultation on “release” of millimetre wave frequencies?