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

In response to the Industry, Science and Economic Development Canada (ISED) consultation (comments due September 6, 2022), experts and Canadian citizens’ groups call for a moratorium on release of more 5G spectrum. Here are some top reasons why.

[PDF of the Joint Statement text, plus Six Reasons for a Moratorium]

Reason #1:  There has been no research on the long-term health effects of mmWaves.

There has been no research on the health effects of long-term exposure to ensure that mmWaves and the new 5G technologies are safe. To quote a U.S. Senator: “So there really is no research ongoing. We’re kind of flying blind here, as far as health and safety is concerned.”[1]

Health Canada itself has admitted that it could not find any human studies that assessed potential health impacts (e.g., cancer, or effects on the eyes, child development, reproduction, cognition, the immune system) of exposure to RF-EMR in the 6–300 GHz frequency range that will be used for 5G technology, including the mmWave frequencies.[2]  

Reason #2:  There is strong scientific evidence that radiation from current (pre-5G) wireless technologies causes serious adverse effects. (5G will worsen the existing problems.)

• Hundreds of high-quality peer-reviewed studies show that exposure to radiofrequency electromagnetic radiation (RF-EMR) from present-day wireless technologies causes serious adverse health effects (e.g., DNA damage, cancer, sperm damage, neurological effects, and more).[3]
• 5G will use those same frequencies, plus it will employ new technologies and add the higher-frequency mmWave bands.
• Children and other susceptible/vulnerable populations are more seriously impacted.
• Scientists specialized in the field have been warning governments that this type of radiation is harmful.  More than 40 appeals calling for standards that are more protective  from RF-EMR have been endorsed by hundreds of researchers and physicians.

Some people experience more immediate, and sometimes debilitating, health effects: Electrohypersensitivity (EHS)

• As with other environmental exposures, some people are more immediately susceptible and overtly affected by wireless radiation. Common symptoms include, among many others: headaches, cognitive difficulties, cardiovascular difficulties and sleep problems. 
• Surveys conducted estimate that 3% to 13% or more of the population experience symptoms of EHS.[4]
• Many are being misdiagnosed or undiagnosed because the medical community is not well-informed about the symptoms and underlying causes.

Wildlife, including birds and pollinators, and plants are also detrimentally affected.

• Research has demonstrated adverse effects of radiofrequency radiation on wildlife, such as birds, amphibians, insects, fish, mammals and plants.  Studies show that RF-EMR 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.[5],[6]

Reason #3:  Health Canada’s exposure guidelines^[7] (Safety Code 6) do not protect Canadians.

These guidelines are:

• based on a 6-minute exposure for far-field exposures (i.e., more than 8 inches from the body) such as from cell tower antenna emissions;
• based on a disproven assumption that tissue must be heated to be harmed (only “thermal” effects are covered). Health Canada dismisses all studies that do not conform with this assumption. Also, Health Canada recently admitted that “there is only limited experimental human data related to human tissue heating by RF energy for frequencies above 6 GHz.”[8]
  The mmWaves ISED plans to release are in the 26, 28 and 38 GHz Bands.
• not based on the most current scientific evidence demonstrating harm, such as DNA damage at levels far below Safety Code 6 maximum limits.

Furthermore,

• Health Canada relies on biased organizations when setting its guidelines — in particular the International Commission on Non-Ionizing Radiation Protection, a self-appointed group that has come under criticism for conflicts of interest.[9],[10],[11],[12],[13]
• Health Canada does not consult Canadians. For example: Until recently, all devices used close to the body at frequencies below 6 GHz had to respect the SAR limit, while those used further from the body had to respect power density limits, 2 to 10 W/m².  Since the new 5G devices that are to be used close to the body would use frequencies above 6 GHz including mmWaves (in addition to presently used frequencies), Health Canada chose to double the power density limit to 20 W/m² for these devices, without consulting Canadians and without long-term experimental data.[14],[15]

Reason #4:  ISED is neither monitoring exposures nor enforcing industry compliance with emissions standards.

• ISED states that it is the responsibility of the companies to ensure that they comply, including considering “combined effects of nearby installations.” ISED claims it “routinely audits the tower sites.”
• However, ISED relies on Spectrum Licences Site Data[16] that is built on data that licensees upload themselves. This data is error-ridden.[17] 
• Data collection and analyses are not standardized, and lack transparency and accountability.  For example, it is unknown how ISED monitors for or assesses “combined effects.”
• Nine out of 10 cell phones on the market in Canada exceed Safety Code 6 guidelines in real use, and yet ISED is taking no action. These devices remain on the market, and in use.[18]
• The Radiation Emitting Devices Act does not mention radiofrequency radiation, nor telecommunications devices, in the law nor regulation.[19]

Reason #5:  Introducing mmWave bands to facilitate the deployment of 5G wireless networks and technologies will also:

• increase risks to individual and business privacy, and cybersecurity.[20],[21]
  • Wireless networks are less secure and more vulnerable to hacking, than wired systems.
  • 5G networks will allow massive amounts of data to be transmitted wirelessly, providing more opportunities to intercept, collect, process, and use personal, financial, strategic or other data, for illegitimate or nefarious purposes.
• interfere with critical satellite data, resulting in an estimated 30% reduction in weather forecast accuracy, and decreased capability to monitor the climate, according to NASA and the US National Oceanic and Atmospheric Administration,[22],[23] and reported to be degrading weather forecasts already in Europe.[24]

“Critically, virtually every sector of the Nation’s economy is weather-sensitive and any degradation of Earth observation data for scientific and operational uses can be expected to have significant negative financial and safety impacts.

“If forecasts of hurricanes, floods, and other natural disasters were degraded, lives and property would be at risk. The profitability of (…) industries, ranging from agriculture and energy to manufacturing and transportation, would also be adversely affected if forecasts become less accurate.”  

– W.P. Mahoney, Associate Director, National Center for Atmospheric Research[25]  

• contribute significantly to climate change and pollution.
  • Wireless technologies consume at least 10 times more power than wired technologies.[26]  
    A 5G base station is expected to consume roughly three times more power than a 4G base station.  Furthermore, 5G will require far more base stations.[27]
  • 5G will cause a substantial increase of e-waste since devices currently used will become obsolete.  E-waste contains toxic and difficult-to-recycle components; only 20% of e-waste is recycled today,[28] and that is often subpar.
  • The exponential growth of wireless technologies is associated with large increases in greenhouse gases, both from the “life cycle” of devices and their use. Greenhouse gas emissions associated with smart phones alone jumped 730% in absolute terms in just 10 years.[29]
• increase the economic burden as a consequence of higher health care costs;[30] lost productivity; security and privacy breaches;[31],[32] agricultural harm; damage caused by the degradation of weather forecast accuracy; and environmental damage.[33]  All of the risks described will translate into tangible costs to Canadian society, which have never been evaluated, nor considered.[34]

Reason #6:  Releasing the mmWave spectrum and encouraging the deployment of 5G technologies contravenes principles of Canada’s Digital Charter.

ISED’s Policy Objectives for the current consultation (section 3) include following the 10 principles of Canada’s Digital Charter.[35] 

• These principles include universal access, a level playing field for business, safety and security, and protection of privacy.  All of these principles would be better served by ensuring that all Canadians have access to fibre optic connections (FTTP) not connected to wireless.  Fibre-optic connections are safe, 100 times faster and more reliable, much less vulnerable to security and privacy breaches, more dependable/resilient in a disaster, and consume one tenth of the energy.[36]

The goal of Canada’s Digital Charter is to establish “a people-centred and inclusive digital economy built on trust.”  ISED’s regulations prevent citizens from opposing a local cell tower on the basis of health or environmental concerns.  Small cell antennas do not even require public notification; nor do low earth orbit satellites.  It is not “people-centred and inclusive” nor does it “build trust” to install antennas close to homes and workplaces, without their knowledge or consent.

Learn more:

Joint Statement calling for a moratorium on 5G expansion

By Canadian experts and citizens’ groups, August 2022

Hundreds of recent scientific reports show “wireless” radiofrequency harms

The 2017 consultation on 5G millimetre wave spectrum — A look back

[1] US Senator Richard Blumenthal, US Senate Hearing on the Future of 5G Wireless Technology, Feb 6, 2019.  https://youtu.be/ekNC0J3xx1w

[2] Health Canada, Analysis of recommended localized human exposure limits for radiofrequency fields in the frequency range, 6 GHz to 300 GHz. p. 32. https://c4st.org/wp-content/uploads/docs/GovRelations/Fed/Health-Canada/Health_Canada_Analysis_of_Recommendations_above_6GHz.pdf

[3] Hundreds of recent scientific reports show harms from “wireless” radiofrequency radiation. https://preventcancernow.ca/hundreds-of-recent-scientific-reports-show-harms-from-radiofrequency-radiation/

[4] 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

[5] Manville, Albert. 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. Submitted to the FCC in 2016. (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)

[6] Protect Birds, Bees and Trees: Include Anthropogenic Radiofrequency Electromagnetic Radiation in Canadian Environmental Protection Act Amendments. White Paper. (April 2022) by Prevent Cancer Now and Canadians for Safe Technology: https://preventcancernow.ca/wp-content/uploads/2022/04/RF-EMRinCEPA-WhitePaper-inclAmendments-PCNC4ST-UPDATED2022April7.pdf

[7] Health Canada. Safety Code 6 – Limits of Human Exposure to Radiofrequency Electromagnetic Energy in the Frequency Range from 3 kHz to 300 GHz. https://www.canada.ca/en/health-canada/services/publications/health-risks-safety/limits-human-exposure-radiofrequency-electromagnetic-energy-range-3-300.html

[8] Health Canada. Analysis of recommended localized human exposure limits for radiofrequency fields in the frequency range, 6 GHz to 300 GHz. Received upon request from Health Canada, by C4ST and PCN. https://c4st.org/wp-content/uploads/docs/GovRelations/Fed/Health-Canada/Health_Canada_Analysis_of_Recommendations_above_6GHz.pdf

[9]  The International Commission on Non-Ionizing Radiation Protection: Conflicts of interest, corporate interests and the push for 5G. Report commissioned, coordinated and published by Members of the European Parliament – Michèle Rivasi (Europe Écologie) and Klaus Buchner (Ökologisch-Demokratische Partei), and financed by the Greens/EfA group in the European Parliament. Brussels, June 2020. https://www.michele-rivasi.eu/wp-content/uploads/2020/06/ICNIRP-report-FINAL-JUNE-2020_EN.pdf

[10] Hardell, Lennart. “World Health Organization, radiofrequency radiation and health – a hard nut to crack (Review).” International Journal of Oncology, vol. 51, 2 (2017): 405-413. doi:10.3892/ijo.2017.4046 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5504984/

[11] Pascual, Gabriel Doménech. “Not Entirely Reliable: Private Scientific Organizations and Risk Regulation – The Case of Electromagnetic Fields.” European Journal of Risk Regulation (Cambridge University Press), Volume 4, Issue 1 (2013): 29-42. https://www.uv.es/gadopas/2013.Not.Entirely.Reliable.pdf

[12]  “There is something utterly wrong with the ICNIRP membership”, Between a Rock and a Hard Place, Science Blog on Mobile Phone Radiation and Health by Dariusz Leszczynski. September 8, 2020. https://betweenrockandhardplace.wordpress.com/2020/09/08/leszczynski-there-is-something-utterly-wrong-with-the-icnirp-membership/

[13]  “The Lies Must Stop: Disband ICNIRP — Facts Matter, Now More Than Ever”, Microwave News, April 9, 2020. https://microwavenews.com/news-center/time-clean-house

[14] 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

[15] Health Canada. Analysis of recommended localized human exposure limits for radiofrequency fields in the frequency range, 6 GHz to 300 GHz. Provided upon request by C4ST and PCN. https://c4st.org/wp-content/uploads/docs/GovRelations/Fed/Health-Canada/Health_Canada_Analysis_of_Recommendations_above_6GHz.pdf

[16] ISED. Spectrum Management System Data. http://sms-sgs.ic.gc.ca/eic/site/sms-sgs-prod.nsf/eng/h_00010.html

[17] A C4ST volunteer, tracking the data since 2016, has discovered hundreds of thousands of duplicate records and other anomalies. When errors are pointed out, they are eventually corrected. However, the Spectrum Management Operations Branch Officer explained in an email that: “The Spectrum Licences Site Data is built upon the data that spectrum licensees upload. ISED regulates them, but the companies are responsible for updating the data.”

[18] Phonegate. Canada: 9 out of 10 cell phones exceed regulatory limits in real use. https://tinyurl.com/2dc5vwa6

[19] Radiation Emitting Devices Act (R.S.C., 1985, c. R-1): https://laws-lois.justice.gc.ca/eng/acts/R-1/ ; Radiation Emitting Devices Regulations: https://laws-lois.justice.gc.ca/eng/regulations/C.R.C.,_c._1370/index.html

[20] Schneier, B. (2019, September 25). 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

[21] The Electronic Frontier Foundation (https://www.eff.org/) offers some in-depth analysis of privacy and security issues. EFF is an independent non-profit that has been working to protect online privacy for nearly thirty years

[22] https://www.washingtonpost.com/weather/2019/05/23/head-noaa-says-g-deployment-could-set-weather-forecasts-back-years-wireless-industry-denies-it/

[23] Spectrum Needs for Observations in Earth and Space Sciences. US House of Representatives Committee on Science, Space, & Technology, Hearing, July 20, 2021. https://science.house.gov/hearings/spectrum-needs-for-observations-in-earth-and-space-sciences

[24] Radio Frequency Interference: an NWP perspective on the RFI 2022 workshop. March 14, 2022. https://www.ecmwf.int/en/about/media-centre/science-blog/2022/radio-frequency-interference-nwp-perspective-rfi-2022

[25] Congressional testimony of William Paul Mahoney III, Associate Director, National Center for Atmospheric Research. 2021. https://science.house.gov/imo/media/doc/Mahoney%20Testimony.pdf

[26] 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

[27] 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

[28] International Telecommunication Union (2020). Creating a circular economy for ICT equipment.   https://www.itu.int/en/mediacentre/backgrounders/Pages/e-waste.aspx

[29] 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/abs/pii/S095965261733233X

[30] Press Conference – Ontario Doctors Warn of Rising Health Care Costs after 5G Roll Out https://www.youtube.com/watch?time_continue=4&v=S16QI6-w9I8

[31]  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

[32] 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

[33] 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.” 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

[34] 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

[35] Canada’s Digital Charter: Trust in a digital world. https://www.ic.gc.ca/eic/site/062.nsf/eng/h_00108.html

[36] Schoechle, Timothy. (2018). Re-Inventing Wires: The Future of Landlines and Networks. National Institute for Science, Law & Public Policy Washington, DC, 156. https://bit.ly/3crWnfV