White Paper UPDATED, including recommended Bill S-5 amendments. Environmental impacts of electromagnetic radiation for telecommunications are not assessed nor regulated in Canada.
This is needed, to protect all biota, particularly insects, birds, and trees.
- Radiofrequency radiation from telecommunications infrastructure can affect flora and fauna. A three-part scientific review (Part 1, Part 2 and Part 3) of the scientific literature recommended regulation of this electromagnetic radiation as pollution. Shortly after completion, long term observations were published showing that Cell Towers Caused Massive Insect Decline on the Greek island of Samos. Bird numbers also declined sharply.
- In the US, the Court of Appeal in the District of Columbia ordered the Federal Communications Commission (FCC) to assess potential environmental harms of radiation for telecommunications.
- Environment and Climate Change Canada (ECCC) is not monitoring, assessing or recommending limits for regulation that focus on protecting the Canadian environment against potential harms from radiofrequency, a.k.a. “wireless radiation.” This gap in environmental protection is increasing with modern technologies.
- Scientific rigour and due process are lacking for human exposure limits. For example, Health Canada recommended human exposure limits were doubled for some 5G frequencies, with no consultation, and inadequate scientific basis.
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).
Environmental effects of RFR
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.
What about scientific due process?
Health Canada increased exposure limits for radiation from 5G technologies, with inadequate justification and no consultation
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:
- Health Canada, with ISED input, discussed the recent doubling of the permitted power density for 24/7 exposure to frequencies intended for 5G technology.
- ECCC confirmed that it 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.”
- ECCC “does not receive notifications or invitations, and is not usually engaged in review of biological and ecosystem impacts of millimetre wavelength radiofrequency radiation.” [These wavelengths are for 5G technologies.]
- ECCC “is not examining energy and resources implications to sustainability and climate change from the use of various alternative technologies for telecommunications.”
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.
Related information, legal context:
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.