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Assess and regulate non-ionizing radiation by amending Bill S-5, Strengthening Environmental Protection for a Healthier Canada Act to introduce a new Section in the Canadian Environmental Protection Act (CEPA).
Proposed amendments to include in Bill S-5
6.1 Section 43 of the Act is amended by adding the following after the last definition in the section:
“radiofrequency electromagnetic radiation” means:
radiated energy arising from accelerating electrical charges, having the form of electromagnetic waves and a stream of photons, and in a vacuum travels at the speed of light. The rate of oscillation of the waves is in the range between 3 kilohertz (kHz) to 300 gigahertz (GHz), which corresponds to the frequency of the non-sinusoidal radio waves typically used in radio communications.
7 Section 44 of the Act is amended by adding the following after subsection (4):
Radiofrequency electromagnetic radiation
(5) The Ministers shall conduct research or studies relating to radiofrequency electromagnetic radiation, methods related to its detection, methods to determine its actual or likely short-term or long-term effect on the environment and human health, and preventive, control and abatement measures to deal with it, and alternatives to its use, to protect the environment and human health.
Ask your Senators and Ministers for CEPA amendments that will make a Right to a Healthy Environment a reality.
In early days of wireless technologies, most attention was paid to human health effects of radiofrequency radiation (RFR) (e.g., Miller et al., 2019). Human exposure limits are recommended in Health Canada’s Safety Code 6, for implementation by Innovation, Science and Economic Development (ISED, previously Industry Canada).
Anything that will harm people may affect many life forms, as the Standing Committee on the Environment of the House of Commons reported following consultation on CEPA. Recommendation 62 in its 2017 report addressed environmental effects of RFR. The Government’s 2018 response indicated that ECCC would study effects on biota. That was never made public.
Today’s increasingly intensive infrastructure and satellites, transferring more data, are emitting more and more complex, pulsed RFR signals. In January 2021 Health Canada announced, with no prior public consultation, doubling of recommended power density for 5G frequencies 6 GHz to 300 GHz. The justification, subsequently published, contended that smaller areas of the body exposed when using personal 5G devices can cope with more intense exposures, compared with whole-body exposures from antennas further away. The scientific report to support higher 24/7 exposures, obtained from Health Canada, is available here. The human studies were limited to very short-term detection of heat and pain, and effects in animals were attributed to the same. Such studies tell us little if anything about harms from lower-level, chronic exposures.
In response, our friends at Canadians for Safe Technology submitted Petition 456 to the Commissioner for Environment and Sustainability, in the Auditor General’s office, and kindly shared the Petition 456 Submission and Government Responses. Of particular note:
These clarifications reinforce the need to amend Bill S-5, Strengthening Environmental Protection for a Healthier Canada Act, to create a Section in the Canadian Environmental Protection Act, 1999 to assess and regulate anthropogenic non-ionizing radiation.
ISED requires compliance with the recommended human exposure limits from Health Canada.
Siting considerations for antennas (CPC-2-0-03) may include local public consultation. Recommended limits according to Safety Code 6 apply to people, on the ground, but this does not cover airspace, nor some terrestrial areas that non-human species of fauna and flora may access.
CPC-2-0-03 references Safety Code 6, and the Canadian Environmental Assessment Act (now the Impact Assessment Act), Species at Risk Act, Migratory Birds Convention Act, and Canadian Environmental Protection Act; however, these Acts do not address non-ionizing radiation nor infrastructure for telecommunications. There are no assessment requirements nor recommended exposure limits with the goal to protect fauna and flora, including birds and insects, in the natural environment.
Other federal Acts such as the Radiation Emitting Devices Act and the Canada Consumer Products Safety Act, that apply to equipment and devices that emit radiofrequency radiation, also reference Safety Code 6. There is no federal measure addressing biota in Canada.