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Health impact of electromagnetic radiation from telecommunication towers located in close proximity to residential areas

Petition: No. 255

Issue(s): Governance, human health/environmental health, science and technology, and other

Petitioner(s): Dennis Noble and Sharon L. Noble

Date Received: 25 June 2008

Status: Completed

Summary: The petitioners allege that electromagnetic radiation emitted from telecommunication towers is causing significant health issues to people living in close proximity to these transmitters. The petitioners raise questions about the objectivity of scientific studies supporting the government’s position related to the potential health hazards of electromagnetic radiation and about the perceived independence of department staff assessing these studies. In addition, the petitioners request that Health Canada invoke the precautionary principle in order to safeguard Canadians.

Federal Departments Responsible for Reply: Health Canada, Industry Canada

Petition

Environmental Petition to the Auditor General
Submitted June 22, 2008

Petitioners:

[Original signed by Sharon L. Noble and Dennis Noble]

Sharon Noble

Dennis Noble

818 Bexhill Place
Victoria, British Columbia
(250) 478-7892


The Auditor General of Canada
Commissioner of the Environment and Sustainable Development
240 Sparks St.
Ottawa, ON
K1A 0G6

Attn. Petitions
Auditor General,

Health Canada's Safety Code 6 was established as a protection against thermal radiation and, therefore, is set at a dangerously high level for all who live close to transmission towers. It provides no protection whatsoever from the real danger to residents: non-thermal electromagnetic radiation. And Health Canada appears only too willing to ignore the health concerns of the residents in order to protect the interests of the telecommunication industry.

We live on the top of Triangle Mountain, in a cul-de-sac with 28 other homes, most of which were built in 1992-1994. At that time there was one small radio tower, which had been there for decades. In, addition there was an amateur radio antenna about 300 meters away on Walfred Road.

Suddenly, in 2000 this was removed and 2 new, tall towers were built and 3 FM transmitters with 2 Studio Link Transmitters (STLs) were installed, location address Fulton Road. These towers are as close as 30 meters from our homes. (Please see attached photos*)

Company

Frequency

Avg. power

Peak power

CIOC-FM ROGERS

98.5 Mhz

47,000 Watts

100,000 Watts

CHTT-FM ROGERS

103.1

9,400

20,000

CFEX-FM CTV

107.3

9,700

20,000

CTV STL

955.525

 

 

ROGERS STL

957.6875

 

 

From the very beginning, the residents experienced harmful interference with their electronic equipment. Despite numerous complaints that continue even to this day and with an emission level in the year 2001 that is more than 1100 times higher than is allowed under the new CPC-2-0-03 guidelines, Industry Canada is quoted as saying: “To date…the Broadcasters have successfully remedied the issues.” (letter of May 26, 2008 from Mr. Neil Allwood, A/Director, Industry Canada, Coastal District Office. To Mayor Jody Twa, Colwood).

But, as harmful as this interference is, and as irritating as Industry Canada’s failure to live up to its obligation is, they are nothing, nothing, in comparison to the real harm the transmitters are causing us.

In 2000, the residents on Bexhill Place expressed concern about the possible health implications and were repeatedly assured that Safety Code 6 provides protection. In 2001, with the help of the City of Colwood, the residents were able to get Industry Canada to perform a test of emission levels, which we later learned was not done with the proper equipment or following the correct protocol. (please refer to page 23 of petition) After a few hours of testing over 2 consecutive days in August, everyone was told the emissions were under Safety Code 6 and therefore there was nothing to worry about.

Before building our home, we asked various authorities about the FM towers and any potential health implications and received repeated assurances that Industry Canada has strict guidelines which ensure that there is no danger from RF emissions. We believed them.

Neighbours soon began to complain about health problems and at a gathering in 2005 many discussed sleeping problems including insomnia and nightsweats, skin rashes, and headaches. We decided to investigate to see if proximity to the transmitters might be the cause.

We’ve since learned that within 1 city block of the towers we have several people with various cancers, neurological problems, multiple miscarriages, and dermatological problems. This was discovered through casual conversations; no survey of the neighbourhood has been done.

We approached Dr. Richard Stanwick, Vancouver Island Health Officer and he told us any problems were Health Canada's responsibility and he could not get involved. In numerous discussions with people at the BC Cancer and Radiation Centre, specifically Dr. Randy Ross, we have received assurance that Safety Code 6 is safe and any health problems are due to other causes. In telephone calls and letters to people at Industry Canada both in Vancouver (Mr. Bruce Drake) and Victoria ( Mr. Jim Laursen) I've received the same response -- so long as the emissions are within the limits set by Safety Code 6, there is nothing that can be done. Through emails, [name withheld] of Health Canada assured us that Safety Code 6 is consistent with the rest of the world’s guidelines and EMR at the non-thermal level is not dangerous.

Over the last year, we’ve learned that the scope of the problem has changed, with Industry Canada's requirement that broadcasters use existing towers wherever possible. Now there is a cell transmitter (869.00 MHz) on the FM towers (no notice was given, so I have no information on the installation date). The tower on Walfred has been removed and new towers were installed, with no notice or consultation. There are now many transmitters of various sorts and we were told by Mr. Laursen that 2 additional cell transmitters will be installed shortly. As of today, there are 44 transmitters within 1 kilometer of our home. (Please see the list from Industry Canada’s website.)

 

NO. ON WALFRED

NO. ON FULTON

1999

1

1

2000

1

5

2008

29

6

According to one of many influential studies : “During the first 3-5 years of exposure, people suffer sleep disorders, melatonin reduction which leads to immune deficiencies. From 5-7 years, neurological problems begin to become noticeable with headaches, confusion, and memory loss. After 10 years, serious disorders such as cancer occur and health damage become irreversible.” (I.S.F. Institute for Stress Research, Berlin, Biological effects of electromagnetic fields on humans in the frequency range of 1 to 3 Ghz).

Most of the people in our neighbourhood have been exposed to these FM towers for 8 years.

We all are on borrowed time and we ask for Health Canada to reduce the allowable exposure level by studying independent, non-industry funded research and heeding the recommendations of the preponderance of credible peer-reviewed international scientists.

We respectfully petition the Auditor General, on behalf of all Canadians:

to have Health Canada and Industry Canada explain their reliance on and association with the telecommunication industry, to the detriment of the health of the citizens by whom they are employed;

to have Health Canada explain why Canadians are not granted the same level of protection that citizens of many other countries are granted;

to instruct Health Canada to revisit its decision regarding Safety Code 6  and to implement a biologically (health)-based standard for non-thermal electromagnetic radiation, patterned after those recommended by the BioInitiative Report, August 2007;

to ensure that all FM and cell phone transmitters presently in use be adjusted to meet this new standard;

to remind Health Canada that its mandate is to enhance and protect the health of Canadians;

to instruct that Health Canada use only scientific studies that are credible, peer-reviewed, non-industry funded that have no industry connections;

to ensure that Health Canada personnel no longer be allowed to have connections with bodies that tend to cast doubt on the impartiality of their work;

to ensure that Industry Canada carryout its mandates as published on their webpage. But while doing so that it respect the concerns of those not in industry but with an interest in decisions that may impact upon them to be properly considered, informed and respected;

to ensure that all dealings with the public be fair, objective, and aboveboard.

We earnestly petition the responders for Health Canada and Industry Canada to provide honest answers that are not mere repetitions of replies that already have been given to us and to many others but which do not respond to the questions.

[Original signed by Sharon Noble and Dennis Noble]

Petitioners:
Sharon and Dennis Noble
818 Bexhill Place
Victoria, British Columbia
V9C 3V5
(250) 478-7892


I. INDEPENDENCE OF ADVISORY BODIES

[Information withheld]

Health Canada and Industry Canada receives great sums of money from the telecommunication industry each through various licensing fees, siting fees, spectrum auctions, etc. For example, according to CanWest News Source, May 28, 2008, more than $560 million was committed by 24 of the 60 participants on the first day of the recent auction of spectrum licenses. It was reported in The Times Colonist of June 18, 2008, page 5B, that “Canada’s auction of the airwaves for wireless services … has raised about $3.77 billion in revenue“ and that the auction is not yet over.

From this arises the perception of a conflict of interest in Health Canada’s and Industry Canada’s responsibility of protecting the citizens of Canada from the potential dangers of electromagnetic radiation emitted by telecommunication transmitters and devices. We undertook to see if perception conflicts with reality:

A. Health Canada Independence

1. In his letter to me of Dec. 17, 2007, [name and position withheld], Consumer and Clinical Radiation Protection Bureau (CCRPB) of Health Canada, stated that "Myself and my colleagues maintain a vigilant surveillance of the health effects literature related to this issue and conduct our own research to evaluate potential bioeffects (such as DNA damage). It is Health Canada's position, and one which I personally agree with, that exposure to radiofrequency fields below the limits outlined in Safety Code 6 do not pose a health risk."

In reply to my request for examples of what Health Canada considers credible studies showing that there are no adverse health effects from non-thermal RF radiation, on March 17, 2008, [name withheld] sent me the following list:

a) [Information withheld]
b) [Information withheld]
c) [Information withheld]
d) [Information withheld] 
e) Ahlbom A, Green A, Kheifets L., Savitz D, Swerdlow A; ICNIRP. Epidemiology of health effects of radiofrequency exposure. Enviro Health Perspect. 112:1741-1754 (2004)

2. I decided to apply [name withheld] "vigilant surveillance" to the quality and integrity of some of [name withheld] sources:

a) [Information withheld] 

[Information withheld]

[Information withheld]

According to the University of Ottawa Gazette, May 10, 2001, "The Canadian project has received a grant from the Canadian Wireless Telecommunications Association (CWTA), which is being administered through the university-industry partnership program of the Canadian Institutes for Health Research (CIHR). CIHR is expected to fund half, with the CWTA funding the remainder. "Industry has a responsibility to contribute to health research on their products, to address questions about potential health risks associated with wireless telecommunications," he says. "The university-industry partnership program that CIHR has set up is exactly designed for this purpose."

In addition, "Roger Poirier, the man who negotiated the million dollar deal, is a consultant on the big cellphone study for IARC," as reported by CBC News, Nov. 25, 2003.

[Information withheld] 

[Information withheld]

b) [Name and information withheld], "has a lucrative consulting practice on EMFs and health. Over the years, [name withheld] has earned hundreds of thousands of dollars disputing the existence of adverse EMF health effects, even those accepted by most other members of the EMF community."

[Name and information withheld]. "Over the last 16 years, only one positive paper on microwave genotoxicity appeared in Radiation Research.... 80% of the negative papers (17 out of 21) published in Radiation Research were paid for by either industry or the U.S. Air Force."

Microwave News is "meticulously researched and thoroughly documented." Time Magazine, July 30, 1990.

“the most authoritative journal on ELF fields and health." Fortune Magazine, Dec. 31, 1990.

"the world's most authoritative source on EMF health risks." Washington Journalism Review, Jan/Feb 1991.

c) [Information withheld]

[Information withheld]

d) [Information withheld]

[Information withheld]

e) [Information withheld]

f) R. Mandeville—President and CSO of Biophage, Inc, a biopharmaceutical company. Company Partners: The Company’s partners include the REGA Institute of the University of Leuven in Belgium, Nymox Inc., the Defence Research Establishment Suffield (DRES) and Biopolymer Engineering of Eagan, MN.

Dr. Mandeville is on the Board of Directors of Montec Holdings, which is directly associated with telecommunication companies. (www.Montecholdings.com/boardofdirectors.htm).

QUESTION:

1) How can Health Canada rationalize using research that is influenced to such a degree by people who rely upon industry for funding?

2) Who in Health Canada is responsible for vetting researchers and the peer-reviewed research used to confirm that Safety Code 6 is safe?

3) Are Health Canada and Industry Canada employees required to sign conflict of interest statements that declare they have no affiliation with any organization that may bring into question the impartiality of their work?

4) Are scientists conducting research for Health Canada and Industry Canada required to sign conflict of interest statements that declare they have no affiliation with any organization, nor do they accept, directly or indirectly, funding from any source that could be perceived in anyway to cast doubt on the objectivity of their work?

5) Do Industry Canada and Health Canada adhere to the rule that the authors, whatever their affiliation, of all studies that Industry Canada or Health Canada depend on to support their position on EMR, must clearly be seen to be independent, and must be willing to declare that they have no financial interests in the outcome of their studies and that they receive no industry funding, whether directly or indirectly, in carrying out their studies?

B. Royal Society

1. According to Artnarong Thansandote, Chief, Electromagnetics Division, CCRPB, Health Canada, in a letter of June 2, 2006, to Pim Vanderveen, Industry Canada, copied to Robert Bradley, Director CCRPB, "...at the request of Health Canada, the Royal Society of Canada assembled an expert panel on radiofrequency (RF) fields to conduct an independent review of the guidelines for safe exposure limits set out in the Code."

Yet even the Expert Panel convened by the Royal Society of Canada to review new scientific studies and to make recommendations about the adequacy of SC6, has persons with close ties to the telecommunications industries. In support of this statement I provide the following:

1. [Information withheld]

2. R.W.Y. Habash has connections with the R. Samuel McLaughlin Centre, which is largely industry-funded. (See WHO 2005 Annual Report) (please refer to #2a)

3. B. Habbick also works for the R. Samuel McLaughlin Centre. (please refer to #2a)

4. [Information withheld]

5. [Information withheld]

6. R. Mandeville, President and CSO of Biophage, Inc a biopharmaceutical company. (refer to #2f for information)

QUESTION:

6) When at least half the members of the "expert panel" have direct or indirect associations with the telecommunication industry, why should the public believe that the recommendations of these people are not influenced by the industry?

7) How does Health Canada refute the perception that it is unduly supportive of telecommunication companies because of its dependence upon researchers who have ties to that industry?

C. WHO

1. a) [Information withheld]

b) [Information withheld] 

c) [Informtion withheld] 

d) [Information withheld]

QUESTION:

8) Since WHO accepts funding from the wireless industry, why should any credence be given to studies that WHO sponsors?

9) Since the researchers appear to be so closely associated with the industry that has a direct interest in the results of their research, why should we not assume that those results are biased in its favour?

II. SCIENTIFIC EVIDENCE

A. Credible Studies?

1. In his letter to me of Dec. 17, 2007, [name withheld] said, "I must point out that while there are some studies reporting evidence of adverse effects from radiofrequency field exposure, there are a much larger (sic) of other studies which do not find similar findings..."

In response to our request for more examples of credible, scientific, peer-reviewed studies that showed the absence of harm from non-thermal radiation, [name withheld] provided 20. Of these 20 studies, 18 were published in 3 journals funded by the telecommunication industry:

Radiation Research, funded by Industry and US Air Force (Microwave News, July 31, 2006.

Bioelectromagnetics Society Journal, funded by Motorola. [Name and position withheld] Motorola. (Microwave News, [information withheld]).

International Journal of Radiation Biology published by Informa Healthcare which, along with its partner, Informa Media and Telecom, are part of the Informa Group Plc.

In explanation of this reliance on industry-funded journals, Microwave News, July 31, 2006, pointed out, [information withheld]. "The assumption here is that industry science is superior to everyone else’s. They make no effort to resolve inconsistent results."

Studies have confirmed that this could apply to industry-funded researchers and research projects regarding radiofrequency dangers.

A comparison of 85 Genotox Studies done from 1990-2006. 45 reported negative effects and 42 reported none. Of the 45 positive report, 3 were industry funded. Of the 42 negative all but 5 were industry funded, and one of these 5 was by [name withheld] of Health Canada who has ties to industry but would not commit whether he was industry funded or not. Microwave News, [information withheld]).

[Information withheld]

Dr. Henry Lai, compared 326 Cell Phone Biological Studies in an internal 2006 study for the Univ. of Washington and found the following:

            Of the studies showing no biological effects, 72% were industry-funded.
            Of the studies showing biological effects, 33% were industry-funded.

Egger, Nat. Inst. Of Environ. Health Science (NIEHS), Vol. 115 #1 Jan 2007: “Health effects of radiofrequency radiation should take sponsorship into account.”

QUESTION:

10) How does Health Canada refute the perception that it discounts credible peer-reviewed scientific studies that are not industry-funded and favors studies that are industry-funded?

11) How does H.C. refute the perception that just as the multibillion dollar asbestos and tobacco industries were able to persuade government overseers to ignore credible evidence harmful to the bottom line of those industries, the multibillion dollar telecommunications industry is not persuading Health Canada to ignore credible evidence that is harmful to the bottom line of that industry?

B. Credible Studies

1. In [name withheld] letter to me of Dec. 17, 2007, [name withheld] said, "When evaluating the scientific evidence for a potential health risk, one must consider all data (not just a selected subset of the literature) to make scientifically sound health risk assessment."

Yet, it is maintained by both HC and the 'expert panel', the Royal Society of Canada, that there has been no new evidence to justify revision of SC 6 since its 1999 review.

Please find below just a few of quite credible studies from around the world that were reported since 1999, showing health effects from non-thermal radiation and, apparently, have been overlooked by the Royal Society of Canada and Health Canada.

REFLEX Report, (December 2004) Risk Evaluation of Potential Environmental Hazards From Low Frequency Electromagnetic Field Exposure Using Sensitive in vitro Methods, A project funded by the European Union under the programme "Quality of Life and Management of Living Resources".

"Twelve institutes in seven countries have found genotoxic effects and modified expressions on numerous genes and proteins after Radio frequency and extremely low frequency EMF exposure at low levels, below current international safety guidance, to living cells in-vitro. These results confirm the likelihood of long-term genetic damage in the blood and brains of users of mobile phones and other sources of electromagnetic fields. The idea behind the REFLEX study was to attempt replicate damage already reported to see if the effects were real and whether, or not, more money should be spent of research into the possible adverse health effects of EMF exposure. They concluded that in-vitro damage is real and that it is important to carry out much more research, especially monitoring the long-term health of people."

Eger H et al, (November 2004) The Influence of Being Physically Near to a Cell Phone Transmission Mast on the Incidence of Cancer, Umwelt Medizin Gesellschaft 17, 4 2004.

"Newly diagnosed cancers were significantly higher among those who had lived for 10 years within 400 metres of the mast, in operation since 1993, compared with those living further away, and the patients had fallen ill on        average 8 years earlier. People living within 400 metres of the mast in Naila had three times the risk of developing cancer than those living further away. This seems to be an undeniable clustering of cancer cases."

Oberfeld G et al, (October 2004) The Microwave Syndrome - Further Aspects of a Spanish Study, Conference Proceedings.

"The adjusted (sex, age, distance) logistic regression model showed statistically significant positive exposure-response associations between the E-field and the following variables: fatigue, irritability, headaches, nausea, loss of appetite, sleeping disorder, depressive tendency, feeling of discomfort, difficulty in concentration, loss of memory, visual disorder, dizziness and cardiovascular problems. The inclusion of the distance, which might be a proxy for the sometimes raised "concerns explanation", did not alter the model substantially."

Hallberg O, Johansson O, (July 2004) Malignant melanoma of the skin - not a sunshine story!, Med Sci Monit. 2004 Jul;10(7):CR336-40.

"A good correlation in time was found for the rollout of FM/TV broadcasting networks while the increased amount of "sun travel" by air (charter) did not start until 7 years after the melanoma trend break in 1955. Counties that did not roll out their FM-broadcasting network until several years after 1955 continued to have a stable melanoma mortality during the intervening years. The increased incidence and mortality of melanoma of skin cannot solely be explained by increased exposure to UV-radiation from the sun. We conclude that continuous disturbance of cell repair mechanisms by body-resonant electromagnetic fields seems to amplify the carcinogenic effects resulting from cell damage caused e.g. by UV-radiation.

Boscol et al. reported that RFR from radio transmission stations affected immunological system in women [Effects of electromagnetic fields produced by radiotelevision broadcasting stations on the immune system of women. Sci. Total Environ 273:1-10, 2001].

Salford et al. (2003) have shown that extremely low doses of GSM radiation can cause brain damage in rats. The authors reported nerve damage following a single two-hour exposure at a SAR of 2 mW/kg. They showed that RF energy can impair the BBB, but they added that the chemicals that leak through the BBB probably damage neurons in the cortex, the hippocampus and the basal ganglia of the brain. The cortex is close to the surface of the skull, while the basal ganglia are much deeper...

BioInitiative Report, August 2007. An international working group of scientists, researchers and public health policy professionals (The BioInitiative Working Group) has released its peer-reviewed report on electromagnetic fields (EMF) and health. By reviewing more than 2000 peer-reviewed studies, they document serious scientific concerns about current limits regulating how much EMF is allowable from power lines, cell phones, and many other sources of EMF exposure in daily life. The report concludes that the existing standards for public safety are inadequate to protect public health.

Clark, M.L. et al, “Biomonitoring of Estrogen and melatonin metabolites among women residing near radio and television radio broadcasting transmitters” concluded that RF and temporally stable 60 Hz exposures were associated with increased E1G excretion among post-menopausal women. J. Occup. Environ. Med. 2007;49: 1149-1156.

QUESTION:

12) How does Health Canada explain why each of these non-industry funded studies is not considered relevant or credible by the experts at HC and the Royal Society?

13) How much has the telecommunications industry spent for research annually over the last 5 years?

14) How much has Health Canada spent for independent, non-industry funded research annually during the last 5 years?

III. OUR PROTECTION?

A. Safety Code 6

1. Health Canada and Industry Canada continue to assure the public that Safety Code 6 is adequate to protect the general public. In [name withheld] letter to me of Dec. 17, 2007, [name withheld] said, "... we would not support Safety Code 6 unless we personally felt it was adequately protective."

The public has been told that we should be comforted by knowing that Canada's Safety Code 6 is one of the most stringent in the world and is consistent with most other western countries.

In reality, “an increasing number of countries have implemented stricter public exposure limits in response to concerns about and studies demonstrating health problems from RF exposure at levels lower than those allowed by SC 6. Many western European countries have done so following the precautionary principle attempting to keep RF exposure as low as possible.

In eastern European and Asian countries, lower standards are being established to protect the public from effects observed in their studies among people chronically exposed to RFs through their work, such as changes in the central nervous, endocrine and immune system functions.’ (Toronto Prudent Avoidance Policy on Siting Telecommunication Towers and Antennas, Nov. 20, 2007).

As reported by the Medical Officer of Health of the Toronto Board of Health in the Siting Policy, “there are already several jurisdictions that have adopted lower exposure limits for the public. Some, such as Bulgaria, China, the Czech Republic, Hungary, Italy, Poland, Russia, and Switzerland have established legally enforceable national levels. Several other local governments have made exposure limits more protective, primarily through cooperative arrangements with industry: Auckland, Brussels, Paris, Salzburg (Austria), and several municipalities in Australia.” In 1999, the Toronto Board of Health recommended exposure limits of .1W/meter squared (1W/m2).

Following are a number of countries and their national standards for 450MHz frequency.

Austria's "precautionary limit

0.001 W/m2

Russia's exposure limit

0.02 W/m2

ECOLOG recommendation 1998

0 023 W/m2

Poland's exposure limit

0.1 W/m2

Italy's exposure limit

0.16 W/m2

CSSR's exposure limit

0.24 W/m2

New Zealand's exposure limit

2.0 W/m2

Canada's exposure limit

3.0 W/m2

Following are the national standards in many countries for 1800MHz frequency.

Toronto Board of Health precautionary

0.10 W/m2

Italy regulatory, precautionary

0.10 W/m2

Switzerland, regulatory, precautionary

0.10 W/m2

China, regulatory

0.10 W/m2

Russia, regulatory

0.10 W/m2

Paris precautionary, cooperative

0.10 W/m2

Salzburg, precautionary, cooperative

0.001 W/m2

ICNIRP Guideline*

10.0 W/m2

Canada

10.0 W/m2

Canada has the same guideline as ICNIRP which says it is only intended to protect the public against short term gross heating effects and NOT against 'biological' effects such as cancer and genetic damage from long term low level microwave exposure from mobile phones, their masts and many other wireless devices. This statement is made at: http://ww.icnirp.de/documents/emfgdl.pdf

QUESTION:

15) Will Health Canada justify the current exposure standards of SC 6, which are at levels to protect the public only against short term gross heating effects, as per ICNIRP?

16) Will Health Canada and Industry Canada amend its public documents to reflect the fact that Canada's standard is not consistent with most other developed countries and to instruct its researchers to stop telling the public that Canada's standards are among the most stringent in the world?

17) Health Canada and Industry Canada do not follow the stricter safety codes of most of Europe but rather the much more lax safety codes of the U.S. To what degree is this because Health Canada and Industry Canada have been unduly influenced by the powerful North American telecommunication industry?

IV. POLICY APPROACHES

The International Commission for Electromagnetic Safety (ICEMS) is a non-profit organization that promotes research to protect public health from electromagnetic fields and develops the scientific basis and strategies for assessment, prevention, management and communication of risk, based on the precautionary principle.

In Dec. 2007 and June 2008 ICEMS and the 47 scientists who were signatories to the Benevento Resolution stated in the follow-up Venice Resolution:

“…we are compelled to confirm the existence of non-thermal effects of electromagnetic fields on living matter, which seem to occur at every level of investigation from molecular to epidemiological…” and urged the immediate adoption of precautionary measures to protect the public. (www.icems.eu).

A. The Precautionary Principle

1. The Precautionary Principle adopted in 1998 at the Wingspread Conference:

"We believe existing environmental regulations and other decisions, particularly those based on risk assessment, have failed to adequately protect human health and the environment, as well as the larger system of which humans are but a part.

We believe there is compelling evidence that damage to humans and the worldwide environment, is of such magnitude and seriousness that new principles for conducting human activities are necessary.

While we realize that human activities may involve hazards, people must    proceed more carefully than has been the case in recent history. Corporations, government entities, organizations, communities, scientists and other individuals must adopt a precautionary approach to all human endeavors.

Therefore it is necessary to implement the Precautionary Principle: Where an activity raises threats of harm to the environment or human health, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically.

In this context the proponent of an activity, rather than the public bears the burden of proof." (the emphasis is mine) (www.sehn.org/wing.html).

2. In several of [name withheld] letters to me, and in response to a question asking [name withheld] for studies that prove that living in the midst of FM and cell transmitters, as we do, is safe, [name withheld] responded in [name withheld] letter of April 3, 2008, “It is technically impossible to ever ‘prove’ that any activity, product, or item is absolutely safe…” In the same letter [name withheld] admits, “There are some studies claiming that biological effects may occur at RF energy levels below SC 6 limits.”

3. According to an Environment Canada pamphlet:

"Canada applies the precautionary approach in situations when a decision must be made about a risk of serious or irreversible harm and where there is scientific uncertainty. These factors should not be used as a reason to postpone decisions. The precautionary approach/principle is a distinctive approach to managing threats of serious or irreversible harm where there is scientific uncertainty. The precautionary approach recognizes that the absence of full scientific certainty shall not be used as a reason to postpone decisions where there is a risk of serious or irreversible harm. Even though scientific information may be inconclusive, decisions have to be made to meet society's expectations that risks be addressed and living standards maintained." (www.ec.gc.ca/econom/pamphlet_e.htm).

B. Risk Assessment

1. Health Canada has publicly subscribed to the Risk Assessment/Management approach that balances harm against cost.

2. But Health Canada and Industry Canada are attempting to redefine the Wingspread precautionary principle, as per their FAQ on Radiofrequency Fields (www.ic.gc.ca/epic/site/smt-gst/nsf/print-en/sf08792e.html#3):

“(21) What is the precautionary principle and when should it be used?

The precautionary principle (PP) is a public policy approach for risk management of possible, but unproven, adverse effects….If you are concerned about RF exposure, you may apply PP by limiting the length of your calls on cell phones and using a “hands-free” device that keeps the cell phone away from your head and body.”

5. Obviously Health Canada and Industry Canada do not understand the precautionary principle to mean the same thing as the Wingspread Conference intended. It is not an approach to manage risk, but to avoid risks where there is a possible threat of serious or irreversible harm.

Health Canada and Industry Canada also confuse precautionary principle with precautionary avoidance, eg. recommending limiting the length of cell phone calls is PA, not PP.

Perhaps Health Canada’s and Industry Canada’s redefining its risk management approach can best be explained by a report presented by Wirthlin, a public relations firm, and Nichols Dezenhall Communications Management, specialists in crisis management. In the report, entitled Industry’s Response to the Precautionary Principal, industry is encouraged to “Conduct research and (http://209.204.197.52/publicns/report/PPFINAL.PDF), as Mr. Vecchia, chairman of ICNIRP advised: "Be realistic about the EMR issue and consider the economical impact of precautionary measures."

QUESTION:

18) Why do Health Canada and Industry Canada require that the risk be established before the precautionary principle is applied when the essential point of the Precautionary Principle is to provide protection in the absence of full scientific certainty?

19) Given the risk involved and the growing body of credible scientific evidence indicating serious harm from non-thermal levels of RF, will Health Canada follow the lead of other Federal Departments (eg. Environment Canada), and implement the original Wingspread Statement on the Precautionary Principle in place of the current risk assessment method of determining the exposure level for the general public?

20) Until and unless the precautionary principle is implemented as intended, would Health Canada and Industry Canada amend their public statements so as to eliminate the possibility of confusing the public about the fact that they are employing risk management, not the precautionary principle?

21) Have Industry Canada and Health Canada changed the label of their risk assessment approach (which emphasizes cost) to the “Precautionary Principle” (which emphasizes safety) in an attempt to co-opt the positive public opinion of the Precautionary Principle without having to change the focus of their approach?

22) Why does Health Canada hold, as stated by [name withheld], that the danger associated with RF must be proven before action is taken, rather than taking the stance, recommended by the Wingspread Conference and Environment Canada, of making the proponent of the product (eg. the telecommunication industry) prove that RF exposure is safe? If it is not possible to prove its safety, as [name withheld] states, then how does Health Canada justify imposing a potentially unsafe product on the Canadian public?

23) How does Health Canada recommend utilizing its avoidance approach by those living next to or under transmission towers 24 hours a day for years on end?

24) Why is it Health Canadas policy that, contrary to the industry standard whereby a new product must be shown to be safe before it is introduced to the public, in the case of cell phones and FM transmitters, they are first introduced to the public and then it becomes the publics obligation to prove them to be unsafe?

25) If Health Canada applied the Precautionary Principle as Environment Canada defines it, new technology would be withheld from public use until it is demonstrated to be safe.

Since to Health Canada the Precautionary Principle is really a synonym for industrys Risk Assessment, are there any tests that new technology must undergo before it is approved for public use?

V. HEALTH IMPLICATIONS

A. Electromagnetic Sensitivity

1. Recent studies in many countries have indicated that more and more people are suffering from electromagnetic sensitivity. The symptoms are varied and severity ranges from mild to debilitating. Sweden now recognizes this as a disability and more people are going on disability pensions each year.

Sweden, Austria, Germany, United States, Switzerland, England and Ireland participated in studies which indicate an increase in the number of people affected which corresponds to the increase in exposure, through more technological development and wider use of transmitters, such as cell phone towers.

As reported in the journal "Electromagnetic Biology and Medicine", 25:189-191, 2006: 190 Hallberg and Oberfeld Table 1 Estimated prevalence of electrosensitive people in different years and countries Measured % El year sensitive Country, reported year Ref. No.:

1985 0.06 Sweden 1991 (0.025–0.125%) National Encyclopedia Sw., 1991
1994 0.63 Sweden 1995 Anonymous est., 1994
1995 1.50 Austria 1995 Leitgeb N. et al., 1995, 2005
1996 1.50 Sweden 1998 SNBHW, Env. report, 1998
1997 2.00 Austria 1998 Leitgeb N. et al., 1998, 2005
1997 1.50 Sweden 1999 Hillert L. et al., 2002
1998 3.20 California 2002 Levallois P., 2002
1999 3.10 Sweden 2001 SValberg PANBHW, Env. report, 2001
2000 3.20 Sweden 2003 Sw Labour Union Sif, 2003
2001 6.00 Germany 2002 Schroeder E., 2002
2002 13.30 Austria 2003 (7.6–19%) Spiß B., 2003
2003 8.00 Germany 2003 Infas, 2003
2003 9.00 Sweden 2004 Elöverkänsligas Riksförbund, 2005
2003 5.00 Schweiz 2005 Bern, Medicine Social, 2005
2003 5.00 Ireland 2005 This is London, 2005
2004 11.00 England 2004 Fox E., 2004
2004 9.00 Germany 2005 Infas, 2004
2017 50.00 Extrapolated to 50%

3. EHS—which can be very debilitating - is thought to result from large changes in the immune system caused by continuing exposure to microwave radiation, leading to chronic inflammation and allergic responses. Estimates of EHS vary from 3% to 10% of the population in the UK and other European countries. (The London Resolution, Dec. 3, 2007).

Canada did not have the technology and number of cell phones as Europe for some time, but it is logical to assume that Canada's exposure is growing at the same rate, and the health complaints are, too.

QUESTION:

Without acknowledging that there is evidence of health effects in humans exposed to non-thermal RF, and with the awareness that Health Canada has publicly subscribed to the risk assessment/management approach that balances harm against cost:

26) What research has Health Canada done to determine the current and future costs to our health system from the effects of EMR?

27) What level of harm will prompt Health Canada to revise its Safety Code 6 guideline to a lower biologically based but, perhaps, more costly level? Please give examples.

B. Consequences of Long-term exposure to FM and cell transmitters

1. Dr. Louis Slevin, editor of the authoritative Microwave News, upon learning that we lived within 100 meters of 3 FM transmitters, warned us that “cell phone transmitters are very dangerous, but FM transmitters can kill you.” (in a telephone conversation on June 18, 2008).

2. There are, and were in 2000, many studies specific to FM transmitters, concluding that prolonged exposure to radiation from these powerful antennae lead to various types of cancer including childhood leukemia. Examples are:

Chiang et al. found that people who lived and worked near radio antennae and radar installations showed deficits in psychological and short-term memory tests [Health effects of environmental electromagnetic fields. Journal of Bioelectricity 8:127-131, 1989].

Dolk H, Shaddick G, Walls P, Grundy C, Thakrar B, Kleinschmidt I, Elliott P. Department of Public Health and Policy, London School of Hygiene and Tropical Medicine, England. PMID: 8982016 [PubMed - indexed for MEDLINE] Am J Epidemiol. 1997 Jan 1;145(1):1-9.

Melanoma Incidence and Frequency Modulation (FM) Broadcasting Ref 3. Hallberg Ö, Johansson O. Melanoma incidence and frequency modulation (FM) broadcasting. Arch Environ Health (2002); 57: 32-40.

Magras & Xenos (1997) have reported irreversible sterility in mice after 5 generations of exposure to 0.168 to 1.053 microwatts per square centimeter in an "antenna park." Note that the current, applicable US exposure standard would be 579 microwatts per square centimeter, -- 500 times higher! -- and that this very low exposure level would relate more to a person living near a Cellular Tower, than a phone user. (http://www.wave-guide.org/library/cellphones.html).

Dr Vini Gautam Khurana is a Mayo Clinic-trained neurosurgeon with an advanced neurosurgery Fellowship in cerebral vascular and tumour microsurgery. He has established that long term exposure and its effects on the body, particularly its electrical organ, the brain, are compounded by numerous other simultaneous long-term exposures including continuous waves from radio and TV transmitter towers, cordless phone base stations, power lines, and wireless/WiFi computing devices. (www.brain-surgery.net.au).

3. According to Report, University of Washington, by Henry Lai, Sept. 2004.

“when considering the health effect of radiation from wireless transmitters, one has to consider the effect of long-term exposure. People who live, attend school, or work close to transmitters are constantly being exposed to the radiation for months or years. Even though the level is low, it would matter if the effects of radiofrequency radiation turn out to be cumulative (eg. add up over time). Small doses cumulate over a long period of time will eventually lead to harmful effects. Therefore, exposure of the general public to radiofrequency radiation from wireless transmitters should be limited to a minimal level.” (www.Salzburg.gv.at/henrylailetterspt132004.PDF).

QUESTION:

28) If Health Canada continuously monitors all relevant scientific information, as they profess, how can it justify having allowed the corporations to install these dangerous transmitters among my neighbours on Triangle Mountain?

C. Consequences of Proximity to FM and cell transmitters

1. Many studies demonstrate that living near (within 300 meters of a base station) is dangerous:

a) A German study found a threefold higher frequency of cancer among people living in the vicinity (400 m) of a GSM base station compared to people living further away from the antenna. The risk for mammary cancer was 3,4 times greater and the average age of contracting this disease was considerably lower, 50,8 years than in the control group (69,9 years). The frequency increased also the longer people had been exposed to the radiation. The study covered a ten year long period (1994-2004), starting the year after the installation of the base station. Before the installation of the base station, there was no difference in cancer incidence between people living in the vicinity of the (future) base station and the control area.

Excerpt:

"The result is a quite concrete epidemiological proof of a connexion between exposition to radiation from GSM Base stations and Cancer. This result is, considering the available documentation about the effect of high frequency electromagnetic radiation not only plausible but probable."

Source (in German): Horst Eger, Klaus Uwe Hagen, Birgitt Lucas, Peter Vogel, Helmut Voit, Einfluss der räumlichen Nähe von Mobilfunksendeanlagen auf die Krebsinzidenz. Umwelt·Medizin·Gesellschaft | 17 | 4/2004.

b) New Austrian research confirms health effects of base station radiation. Despite exposure to radiation far below recommended levels (max. 4.1 mW/m2), effects on wellbeing and performance on cognitive tests was observed in a study of 365 subjects living within 20-600 metres from Mobile Phone Base stations.

Source: Hutter HP, Moshammer H, Wallner P, Kundi M. Subjective symptoms, sleeping problems, and cognitive performance in subjects living near mobile phone base stations. Occup Environ Med. 2006 May;63(5):307-13.

c) Studies “on symptoms experienced by people living in vicinity of base stations shows that, in view of radioprotection, minimal distance of people from cellular phone base stations should not be < 300 m.” Physicians and Scientists for Responsible Application of Science and Technology, June 15, 2008.

d) Clark, M.L. et al, “Biomonitoring of Estrogen and melatonin metabolites among women residing near radio and television radio broadcasting transmitters” concluded that RF and temporally stable 60 Hz exposures were associated with increased E1G excretion among post-menopausal women. J. Occup. Environ. Med. 2007;49: 1149-1156.

QUESTION:

29) Given than many people living in proximity to these are suffering serious diseases which are consistent with those attributable to chronic exposure to radiation from FM transmitters, what will Health Canada do to enforce removal of these transmitters to non-residential areas?

30) Given that these FM transmitters are in close proximity to and directed toward schools, and given that children are more susceptible to radiation danger, how will Health Canada and Industry Canada respond to concern from parents about their childrens health?

C. Antenna Farms

1. “In releasing Professor Dobell's review, Minister Rock acknowledged the Mayor, City Council and citizens of Colwood as having helped inspire the National Antenna Consultation, announced in October 2002. The National Antenna Tower Policy Review will give all Canadians the opportunity to shape the Department's tower siting procedures to ensure they keep pace with an evolving technological and consumer environment to best meet citizens' concerns.” (Industry Canada’s Minister Releases Third Party Review of Triangle Mountain Antenna Towers Siting Process, Feb. 6, 2003.)

2. In its circular CPC-2-0-03 effective Jan. 1, 2008, Industry Canada in section 3 states:

"Before building a new antenna-supporting structure, Industry Canada requires that proponents first explore the following options:

1) consider sharing an existing antenna system, modifying or replacing a structure if necessary;
2) locate, analyze and attempt to use any feasible existing infrastructure such as rooftops, water towers, etc."

3. In layman's term, such arrangements are called 'antennae farms', where multiple transmitters are grouped on one towers. When I asked why this was being encouraged, I was told by Jim Laursen, a local IC official, that people didn't object to transmitters but they do object to towers.

Industry itself admits, as stated in the Canadian Association of Broadcasters' submission, Oct. 17, 2003, "electromagnetic field levels in excess of HC's limits may be produced on the site if additional facilities are added."

[Information withheld]

4. Narda, the leading manufacturer of equipment to measure all aspects of EMR, used by Industry Canada in its field surveys, states that today’s multi-emitter transmission sites present difficulties for

“accurate RF emissions measurements. Multiple emitters dramatically complicate the measurement process, and it is quite easy to make measurements that appear accurate but are, in fact, quite the opposite. The fact that data gathering must be conducted in the field at sites where there are other transmitting systems besides the one to be measured compounds measurement difficulties. The emitters may also operate at different frequencies, invoking more than one level of acceptable exposure as defined by today’s frequency-dependent standards.
The antennas for these systems are usually located within a stone‘s throw of each other. Without the ability to discriminate among signals, it is almost impossible to determine the radiation level of a specific emitter. In addition, diode detectors that have often been used for electric and magnetic field measurements in the broadcast industry have characteristics that make their accuracy questionable in these applications.” (Narda East Product Brochure).

(Please note: Even with improper equipment and giving no consideration for compounding effects of multiple transmitters, the measurements taken by Industry Canada in my neighbourhood in 2001 were as high as 115 microwatts per square centimeter, or up to 685 times higher than those used in the Magras & Xenos study (see page. 17). And since 2001, many more antennae have been added within 300 meters, with plans for more. Canada's Safety Code 6 allows 200 microwatts per square centimeter for the general public.)

5. In the Canadian Association of Broadcasters submission to Industry Canada as part of the Antenna Policy Review, Oct. 17, 2003, the broadcasters state one of the key licensing conditions imposed by IC is that all RF installations must meet the requirements of HC with respect to non-ionizing RF fields, as set out in SC 6. Engineering submissions supporting applications for new or modified facilities (eg. antenna farms) must include a technical analysis demonstrating that the facilities will not exceed the levels of SC 6. This is done by making "theoretical signal-level calculations."

In the same submission, the broadcasters state that "although the effective radiated power from FM/TV/DAB broadcasting installations can often be quite high, tall antenna towers are generally used. This automatically ensures that high-energy zones are located well above the ground.

In all of my research I have been unable to find even one long-term study of the effects of these antenna farms on nearby residents.

QUESTION:

It is uncontested that when wireless electronic equipment is added in an already existing EMR zone that the result is a compounding of emissions.

In light of the recent study BY Dr. Khurana regarding the impact of the compounding effects of multi-product use, without acknowledging that the evidence of documented health effects in animals or humans exposed to non-thermal levels of radiation is conclusive, and in the interest of protecting Health Canada from a future charge of failing in its fiduciary responsibility to protect the health of its citizens, and in mitigating somewhat the possibility of the telecommunications industry from being held liable for injuries caused by EMR:

31) Will Health Canada advocate/support the placing of warning signs within 200 meters of the transmitter sites with the wording?

WARNING! YOU ARE ENTERING AN AREA OF HIGH ELECTROMAGNETIC RADIATION EMISSIONS. USE OF WIRELESS EQUIPMENT, INCLUDING CELL PHONES, WITHIN A RADIUS OF 200 METERS OF THESE TRANSMITTERS IS TO BE AVOIDED.

32) Who is responsible for establishing the parameters for technical analyses associated with multiple transmitters?

33) Do these "theoretical calculations" take into consideration the fundamental properties of EM fields, namely reflection and compounding?

34) How does Ind. Can. ensure that the allowable limits for maximum values are never exceeded?

35) With the knowledge that "the effective radiated power from FM/TV/DAB broadcasting installations can often be quite high", why has Health Canada allowed, and continues to allow, installations of these transmitters near homes and schools which are at or near the same elevation of the transmitters? Please justify this practice.

36) Why is Industry Canada taking the approach of requiring the placement of multiple transmitters on towers? Is it, as I have been told by Mr. Jim Laursen of Industry Canada, because people see the towers and complain; they don't see the transmitters and don't complain?

37) Upon what scientific evidence does Health Canada base its decision to force proliferation of these antenna farms near residences and schools?

38) Under the new siting policy, CPC-2-0-03, no consultation is required for placement of new transmitters, only for new towers. Why was this presented to the public as an effort for more consultation between Ind. Can. and the public when it really was intended to allow the creation of antenna farms with no consultation with or input by the public?

D. OUR SITUATION

1. In the study entitled “Biomonitoring of Estrogen and melatonin metabolites among women residing near radio and television radio broadcasting transmitters” M.L. Clark, et al, concluded that RF and temporally stable 60 Hz exposures were associated with increased E1G excretion among post-menopausal women. J. Occup. Environ. Med. 2007;49: 1149-1156.

The study took place at Lookout Mountain, Colorado, where people live with multiple FM and TV antennae. Results of the long-term study showed that long-term exposure to RF results in increases in estrogen in post-menopausal women and reduction in melatonin production, both of which have been shown to be related to cancer.

It should be pointed out that the closest house to the transmitters was 900 meters away and the scientists conducting the study considered, for their purposes, a high exposure level to be anything greater than 4 microwatts per centimeter squared.

2. However, I and my neighbours who live on top of Triangle Mountain live at nearly the same elevation as the FM and cell transmitters, and some live as close as 30 meters from them. Even with inadequate testing methods, which I will detail in the following section, the exposure level in the Triangle Mountain study was as high as 114 microwatts per centimeter squared and today there are 10 times the number of transmitters here than there were in 2001. There are 44 transmitters of varying frequencies within 1 kilometer of my home, 55 within 2 kilometers.

And within approximately one kilometer there are two schools, an elementary school and a middle school, in direct line with the transmissions.

3. The Triangle Mountain study:

In August 2001, at the request of the City of Colwood and the residents of Triangle Mountain, two experts from Industry Canada spent 2 days at 10 different locations, measuring emission levels, in an effort to provide reassurance that health was not endangered by 3 FM transmitters and 2 Studio Link Transmitters (STLs) that were installed in 2000.

According to Safety Code 6,6.1: “the objective of a survey is to determine whether the device or installation complies with recommended standards of performance and personnel exposure….”

a) SC 6, 6.1f says that equipment shall match the source and the exposure levels in the near- and far-field.

According to the report written by [name withheld], the spectrum analyzer was used merely to find the FM emissions, not to measure them. Instead, an electronic survey meter and a Narda field probe were used. According to an independent expert with whom I consulted, this means that not all RF emissions were measured from the STLs or other nearby transmitters.

In addition, according to Narda specifications, the Narda field probe that was used is “very suitable for Occupational Exposure levels and partially suitable for General Public Levels.

Conclusion:

The correct equipment for the situation was not used.

b) SC 6, 6.2a says that records shall be kept for all RF survey measurements, including calibration date, and, SC 6, 6.1f says that survey instruments shall be fully calibrated at least every 3 years.

No calibration data was provided with the report and when, in Oct. 2007, [name withheld] of Industry Canada, who performed the tests, was asked for the data, [name withheld] said it had not been kept. But [name withheld] replied that some of equipment had last been calibrated on March 19, 1998, or 3 ½ years before the test.

Inconsistencies in the results were noted in the report and readings could not be duplicated, a clear indication that the equipment was not performing properly.

Conclusion:

Industry Canada’s protocol regarding equipment and record keeping was not followed.

c) SC 6.2.2.1a requires that testing be done using a time averaging over a period of .1 hour (6 minutes).

Industry Canada reported that a 30 second averaging method was used.

Conclusion:

Industry Canada’s protocol regarding time averaging was not followed.

d) Narda, the equipment manufacturer, states that the antenna should be at head level (1.5-1.75 meters) and should be placed on a non-conducting tripod connected to a basic unit via cable. This ensures that the field being measured is not influenced by the unit or the tester.

The Industry Canada report describes how the probe was moved slowly up and down as the surveyor held it and walked back and forth. “The probe was held high over his head, pointing the probe away from the body.” Variable readings were explained by the movement of nearby people.

Conclusion:

Neither manufacturer nor Industry Canada’s instructions for testing were followed.

e) SC 6.2.4.3 states that if measured strengths are as high as 20% of limits, induced and contact current measurements should be taken.

No such measurements were taken even though readings were reported to be as high as 54.5% .

Conclusion:

Industry Canada’s protocol was not followed.

Even using improper equipment and incorrect protocol, the highest reported reading was 20.3 V/m or 109 uW/cm2. (When the calculations were checked for accuracy, the highest reading actually was 20.7 W/m or 114 uW/cm2 outdoors and 75 uW/cm2 indoors.)

To put this into perspective, the precautionary maximum set by the BioInitiatve Report is .1 uW/cm2 outdoors and .01uW/cm2 indoors, 7500 times lower than the results from the measurements done in 2001 inside a home where people live, exposed, for 24 hours a day.

4. It should come as no surprise, then, that there are many people on my street suffering severe diseases: sleep disorders, memory reduction, loss of concentration, multiple miscarriages, skin rashes, multiple cataracts, prostate cancers, breast cancers -- all within one city block of the FM transmitters.

Whenever I have written to Health Canada or to Industry Canada informing them about our problems, I've been told the emissions are within Safety Code 6 levels for the general public. Therefore 1) there is nothing I can do; 2) there is no proof of a connection between the illnesses and electromagnetic radiation from the transmitters.

5. 21:08 06.08.2006 "microwave radiation can...functionally interfere with the natural processes involved in DNA replication and repair, by subtly altering molecular conformation (architecture), for example; this could well account, respectively, for the reports of chromosome aberrations / micronuclei formation and for the increased amount of DNA fragmentation observed under irradiation." Source: How Exposure to GSM & TETRA Base-station Radiation can Adversely Affect Humans. By Dr Gerard Hyland.

QUESTION:

39) Please define "general public" as the term is used in Safety Code 6.

40) If, as according to ICNIRP, levels allowed by Safety Code 6 apply to short-term acute exposure, why are there no biologically (health)-based standards which apply to chronic, long-term exposures for people who are living with the transmitters 24 hours a day, 365 days a year?

41) Would Industry Canada provide the power level of each of the 55 transmitters within 2 kilometers of my home?

42) Does Industry Canada have a limit to the number of transmitters that will be added within this radius?

43) Would Health Canada commit to having an independent epidemiological study done to determine the health status of people on Triangle Mountain?

44) Would Health Canada commit to an immediate and independent investigation into the dangers posed by antenna farms and, should these show harm, would it commit to establishing biologically (health)-based exposure standards?

45) Considering the improper procedures and equipment used in the 2001 testing for EMR on Triangle Mountain, why should the residents of Colwood have any confidence in Health Canada’s and Industry Canada’s assurances that they are safe since the actions of their employees left them in no position to offer an opinion?

46) Given the lack of concern for the public demonstrated by their employees at every level, why should the citizens of Canada have confidence in anything Health Canada or Industry Canada says or does?


Closing Statement

It is strikingly clear to us that Canada is in desperate need of a Corporate Manslaughter Act. The UK enacted one in 2007. It came into force in April, 2008. It made public and private corporations, as well as agents of these corporation, criminally responsible for actions that result in a person’s death. The Act, and offence, also applies to Crown bodies.

With such an act in place here in Canada, there would be no need to have written this petition.

It is particularly offensive to us that the telecommunications industry appears to have such an influence over governmental departments that it can deleteriously impact the public weal. It has led to the bizarre situation in which the citizens of Canada are forced to act as guinea pigs testing potentially harmful telecommunications technology.

But this was to be expected when Canada allowed the telecommunications industry to introduce its products before any testing was done to prove them safe. Now it is up to the Public, by epidemiological studies showing their tumours, lesions, heart problems, sleep disorders, childhood leukemia, and cancers, to prove them unsafe.

Easy enough, you might think, if the evidence is that clear. Ah, but what matter clarity when it is industry, abetted by their Faustian enablers within Health Canada and Industry Canada, that has the final say. Not for nothing comes the proverb: “He who pays the piper, calls the tune.”

And to prove the faith that industry has placed in them has not been misapplied, Health Canada and Industry Canada have now gone so far as to improvise on a theme made infamous in Orwell’s classic, 1984. Every schoolboy remembers “War is Peace” and “Slavery is Freedom”. But they‘ll never place: “Cost is Harm” “Risk Management is the Precautionary Principle” and “Precautionary Avoidance is Living Under Transmission Towers.”

Ah, yes, indeed, it is a brave new world today. But will we be around to enjoy tomorrow?

*[attachments not posted]

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Joint Response: Health Canada, Public Health Agency of Canada

5 November 2008

Ms. Sharon and Mr. Dennis Noble
818 Bexhill Place
Victoria, British Columbia V9C 3V5

Dear Ms. and Mr. Noble:

This is in response to your environmental petition no. 255 of June 22, 2008, addressed to Mr. Scott Vaughan, the Commissioner of the Environment and Sustainable Development (CESD).

In your petition you raised concerns about the effects of electromagnetic radiation.

I am pleased to provide you with the enclosed joint Health Canada and Public Health Agency of Canada response to your petition. I understand that the Minister of Industry will be responding separately to the questions that fall within the purview of his department.

I appreciate your interest in this important matter, and I hope that you will find this information useful.

Yours sincerely,

[Original signed by Leona Aglukkag, Minister of Health]

Leona Aglukkaq

Enclosure

c.c. Mr. Scott Vaughan, CESD
The Honourable Tony Clement, P.C., M.P.


Response to Environmental Petition No. 255
filed by Ms. Sharon Noble and Mr. Dennis Noble
under Section 22 of the Auditor General Act
Received July 9, 2008

Effects of Electromagnetic Radiation (EMR)

November 6, 2008

Minister of Health and the Minister for the Federal Economic
Development Initiative for Northern Ontario

1. How can Health Canada rationalize using research that is influenced to such a degree by people who rely upon industry funding?

5. Do Industry Canada and Health Canada adhere to the rule that the authors, whatever their affiliation, of all studies that Industry Canada or Health Canada depend on to support their position on EMR, must clearly be seen to be independent, and must be willing to declare that they have no financial interests in the outcome of their studies and that they receive no industry funding, whether directly or indirectly, in carrying out their studies?

7. How does Health Canada refute the perception that it is unduly supportive of telecommunication companies because of its dependence upon researchers that have ties to that industry?

9. Since the researchers appear to be so closely associated with industry that has a direct interest in the results of their research, why should we not assume that those results are biased in its favour?

10. How does Health Canada refute the perception that it discounts credible peer-reviewed scientific studies that are not industry funded and favours studies that are industry funded?

11. How does HC refute the perception that just as the multibillion dollar asbestos and tobacco industries were able to persuade government overseers to ignore credible evidence harmful to the bottom line of those industries, the multibillion dollar telecommunications industry is not persuading Health Canada to ignore credible evidence that is harmful to the bottom line of that industry?

12. How does Health Canada explain why each of these non-industry funded studies is not considered relevant or credible by experts at HC or the Royal Society?

Answer to Questions 1, 5, 7, 9, 10, 11 & 12:

Health Canada’s Safety Code 6 sets out safety requirements for the installation and use of radiofrequency (RF) and microwave devices that operate in the frequency range from 3 kHz to 300 GHz. It is based on internal scientific reviews of original relevant scientific studies that are published in internationally recognized peer-reviewed journals. For further information, please refer to http://www.hc-sc.gc.ca/ewh-semt/pubs/radiation/99ehd-dhm237/index-eng.php.

All credible peer-reviewed scientific studies are included in Health Canada’s weight-of evidence approach. Each study is evaluated individually for its scientific quality, the important factors being proper scientific design and analysis. The fact that some studies are either directly or indirectly funded, in whole or in part, from the wireless industry or any other sources does not constitute a valid reason to dismiss these research findings outright. The only scientifically justifiable approach is to evaluate the science in each study based upon its merits and deficiencies and then roll up the analysis using a weight-of-evidence approach.

Health Canada conducts its own analysis of the scientific literature in a completely independent fashion. All research, review and surveillance activities in the area of bioelectromagnetics health risk assessment by Health Canada have been solely funded by the Government of Canada. Health Canada is not dependent on any external parties for its risk assessment of the safety of RF fields.

Health Canada cannot control such perceptions about the adequacy of the scientific process used to evaluate scientific studies. We endeavour to maintain an open and fair environment for scientific discourse and respond to any questions regarding the evaluation process.

2. Who in Health Canada is responsible for vetting researchers and the peer-reviewed research used to confirm that Safety Code 6 is safe?

Safety Code 6 was written by a team of scientists at Health Canada as stated in the document. The proposed guidelines were reviewed by a number of internal and external referees, including the Royal Society of Canada’s (RSC) Expert Panel on Radiofrequency Fields. It is important to point out that the health effects literature reviewed by Health Canada staff is the same as that reviewed by all other national and international standards organizations. The safety limits outlined in Safety Code 6 are consistent with other international science-based exposure limits.

3. Are Health Canada and Industry Canada employees required to sign conflict of interest statements that declare they have no affiliation with any organization that may bring into question the impartiality of their work?

4. Are scientists conducting research for Health Canada and Industry Canada required to sign conflict of interest statements that declare they have no affiliation with any organization, nor do they accept, directly or indirectly, funding from any source that could be perceived in any way to cast doubt on the objectivity of their work?

Answer to Questions 3 & 4:

Health Canada staff adhere to the Values and Ethics Code for the Public Service and make declarations of conflict of interest as required. All work performed by Health Canada staff in this area has been entirely funded by the Government of Canada.

6. When at least half of the members of the “expert panel” have direct or indirect associations with the telecommunication industry, why should the public believe that the recommendations of these people are not influenced by industry?

The RSC is a highly reputable organization which is composed of esteemed scientists. Health Canada contracted with the RSC to independently select an expert panel to review Safety Code 6 and the scientific basis for its exposure limits for the protection of the public from RF fields. While Health Canada wrote the terms of reference for the tasks of the Expert Panel, the selection of Panel members was done entirely by the RSC and Health Canada had no part in the research, review and development of the conclusions and recommendations presented by the panel.

8. Since WHO accepts funding from the wireless industry, why should credence be given to studies that WHO sponsors?

The World Health Organization (WHO) is a highly reputable international science-based organization which is composed of a diverse set of esteemed scientists from around the world in a variety of disciplines.

The fundamental purpose of the WHO EMF project is to advise and assist national health authorities to develop protection measures for their populations from exposure to electromagnetic fields. This is especially valuable for smaller countries lacking the scientific infrastructure to undertake their own reviews and develop guidelines. Countries are not obligated to accept the recommendations of the WHO and are free to formulate their own protective measures. This is the case in Canada, where Safety Code 6 was one of the first national exposure guidelines developed and continues to be supported by the scientific community.

The WHO EMF project receives funding from many national health authorities and private industry. However, the WHO EMF project does not fund research studies, but rather reviews the literature and identifies knowledge gaps which require further research.

14. How much has Health Canada spent for independent, non-industry funded research annually during the last 5 years?

Research in the field of bioelectromagnetics conducted by Health Canada scientists is solely funded by the Government of Canada. Since 2003, Health Canada has spent a total of approximately $500,000 plus approximately 15 person-years of staff time on EMF research, evaluation, survey and surveillance activities.

15. Will Health Canada justify the current exposure standards of SC6, which are at levels to protect the public only against short term gross heating effects, as per ICNIRP?

Health Canada’s Safety Code 6 takes into account all possible biological and/or health effects of RF fields, including short-term heating effects, non-thermal effects and/or long-term effects. It should also be pointed out that the exposure standards of Safety Code 6 are applicable for continuous, uninterrupted exposure (24 hours per day, 7 days per week) and not only for short-term or intermittent exposure.

16. Will Health Canada and Industry Canada amend its public documents to reflect the fact that Canada’s standard is not consistent with most other developed countries and to instruct its researchers to stop telling the public that Canada’s standards are among the most stringent in the world?

17. Health Canada and Industry Canada do not follow the stricter safety codes of most of Europe but rather the much more lax safety codes of the U.S.. To what degree is this because Health Canada and Industry Canada have been unduly influenced by the powerful North American telecommunication industry?

Answer to Questions 16 & 17:

The basic restrictions outlined in Health Canada’s Safety Code 6 guideline are similar to both the Standard for Safety Levels with Respect to Human Exposure to Radio Frequency Electromagnetic Fields, 3 kHz to 300 GHz (IEEE C95.1) and International Commission on Non-Ionizing Radiation Protection (ICNIRP) guidelines, adopted by most Western European nations and the United States. The Guidelines can be found at the following links: http://www.icnirp.net/documents/emfgdl.pdf, and http://standards.ieee.org/reading/ieee/std_public/description/emc/C95.1-1991_desc.html.

Health Canada’s Safety Code 6, however, is more restrictive in terms of compliance. It requires Specific Absorption Rates (SAR) evaluations to be conducted using an averaging volume of 1 g of tissue, whereas a 10 g volume is used for both IEEE C95.1 and ICNIRP guidelines. This means greater accuracy with Safety Code 6.

As described above, Health Canada’s recommendations regarding safety of exposure to RF fields have not been influenced by the telecommunications industry in any way.

18. Why do Health Canada and Industry Canada require that the risk be established before the precautionary principle is applied when the essential point of the Precautionary Principle is to provide protection in the absence of full scientific certainty?

19. Given the risk involved and the growing body of credible scientific evidence indicating serious harm from non-thermal levels of RF, will Health Canada follow the lead of other Federal Departments (eg. Environment Canada), and implement the original Wingspread Statement of the Precautionary Principle in place of the current risk assessment method of determining the exposure level for the general public?

20. Until and unless the precautionary principle is implemented as intended, would Health Canada and Industry Canada amend their public statements so as to eliminate the possibility of confusing the public about the fact that they are employing risk management, not the precautionary principle?

21. Have Industry Canada and Health Canada changed the label of their risk assessment approach (which emphasizes cost) to the “Precautionary Principle” (which emphasizes safety) in an attempt to co-opt the positive public opinion of the Precautionary Principle without having to change the focus of their approach?

25. If Health Canada applied the Precautionary Principle as Environment Canada defines it, new technology would be withheld from public use until it is demonstrated to be safe. Since to Health Canada the Precautionary Principle is really a synonym for industry’s Risk Assessment, are there any tests that new technology must undergo before it is approved for public use?

Answer to Questions 18, 19, 20, 21, & 25:

Health Canada endorses the precautionary principle and its approach to decision making can be found online at http://www.hc-sc.gc.ca/sr-sr/advice-avis/decision/index-eng.php.

Health Canada’s position and public statements are consistent with the Precautionary Principle. If the guidelines in Safety Code 6 are respected, then there is no convincing scientific evidence to expect any adverse human health effects.

22. Why does Health Canada hold, as stated by [name withheld], that the danger associated with RF must be proven before action is taken, rather than taking the stance, recommended by the Wingspread Conference and Environment Canada, of making the proponent of the product (eg. the telecommunication industry) prove that RF exposure is safe? If it is not possible to prove its safety, as [name withheld] states, then how does Health Canada justify imposing a potentially unsafe product on the Canadian public?

Health Canada staff do not advocate that the dangers associated with RF must be proven before action is taken. If the guidelines in Safety Code 6 are respected, Health Canada’s position is that there is no convincing scientific evidence to expect any adverse human health effects. Health Canada does not impose, regulate, license or monitor the compliance of wireless technologies in Canada. These activities are responsibilities of the Department of Industry.

23. How does Health Canada recommend utilizing its avoidance approach by those living next to or under transmission towers 24 hours a day for years on end?

28. If Health Canada continuously monitors all relevant scientific information, as they profess, how can it justify having allowed the corporations to install these dangerous transmitters among my neighbours on Triangle Mountain?

29. Given that many people living in close proximity to these are suffering serious diseases which are consistent with those attributable to chronic exposure to radiation from FM transmitters, what will Health Canada do to enforce the removal of these transmitters to non-residential areas?

30. Given that these FM transmitters are in close proximity to and directed toward schools, and given that children are more susceptible to radiation danger, how will Health Canada and Industry Canada respond to concern from parents about their children’s health?

31. Will Health Canada advocate/support the placing of warning signs within 200 meters of the transmitter sites with the wording?

WARNING! YOU ARE ENTERING AN AREA OF HIGH ELECTROMAGNETIC RADIATION EMISSIONS. USE OF WIRELESS EQUIPMENT, INCLUDING CELL PHONES, WITHIN A RADIUS OF 200 METERS OF THESE TRANSMITTERS IS TO BE AVOIDED.

35. With the knowledge that “the effective radiated power from FM/TV/DAB broadcasting installations can often be quite high”, why has Health Canada allowed, and continues to allow, installations of these transmitters near homes and schools which are at or near the same elevation of the transmitters? Please justify this practice.

37. Upon what scientific evidence does Health Canada base its decision to force proliferation of these antenna farms near residences and schools?

Answer to Questions 23, 28, 29, 30, 31, 35, & 37:

Health Canada is not responsible for siting, licensing or compliance of wireless transmitters. Those activities are the responsibility of Industry Canada.

It is Health Canada’s scientific position that there are no anticipated adverse health effects associated with short-term or long-term exposure of the general public to RF fields, provided that exposure levels are below the limits outlined in Safety Code 6.

It is Health Canada’s opinion that there is no scientific justification for such a warning. However, it is the responsibility of Industry Canada to determine whether warning signs are warranted.

24. Why is it Health Canada’s policy that, contrary to the industry standard whereby a new product must be shown to be safe before it is introduced to the public, in the case of cell phones and FM transmitters, they are first introduced to the public and then it becomes the public’s obligation to prove them to be unsafe?

In the case of cellular technology, exposure guidelines existed (1979 in Canada) well before the introduction of the technology (about the late 1980’s in Canada). A large body of scientific research also existed before the introduction of the technology, much of which looked at the possibility of non-thermal effects. Health Canada does not promote, regulate, license or monitor the compliance of wireless and broadcast technologies in Canada. These activities are the responsibilities of the Department of Industry. There is no convincing scientific evidence that exposure to RF fields at levels below the limits outlined in Safety Code 6 cause any adverse health effects.

26. What research has Health Canada done to determine the current and future costs to our health care system of EMR?

Health Canada has not assessed the possible costs to the health care system from exposure to electromagnetic radiations (EMR) since there is no convincing scientific evidence of adverse health effects as long as the exposure limits outlined in Safety code 6 are respected.

27. What level of harm will prompt Health Canada to revise its Safety Code 6 guideline to a lower biologically-based but, perhaps, more costly level? Please give examples.

Any credible, independently replicated and consistent adverse health effect that is demonstrated to arise from RF field exposures below the limits outlined in Safety Code 6 would prompt Health Canada to revise its exposure limits.

39. Please define “general public” as the term is used in Safety Code 6.

The term “general public” is defined in Safety Code 6 (Appendix VIII, Definitions, page 67) as follows: “All persons not employed as RF and microwave exposed workers or those not working in controlled environments (areas). They include pregnant women, the aged, children, the chronically ill and disabled”. For more information, please refer to the following link: http://www.hc-sc.gc.ca/ewh-semt/pubs/radiation/99ehd-dhm237/index-eng.php.

40. If, as according to ICNIRP, levels allowed by Safety Code 6 apply to short-term acute exposure, why are there no biologically (health)-based standards which apply to chronic, long-term exposures for people who are living with the transmitters 24 hours a day, 365 days a year?

Health Canada’s Safety Code 6 takes into account all possible biological and/or health effects of RF fields, including short-term heating effects, non-thermal effects and/or long-term effects.

43. Would Health Canada commit to an independent epidemiological study done to determine the health status of people on Triangle Mountain?

Conclusions from a WHO expert workshop, published in 2007, state that public exposures to permissible RF levels from mobile telephone and base stations are not likely to adversely affect human health. Based on current evidence of health effects, the Public Health Agency of Canada has no plans to carry out an independent epidemiological study in Triangle Mountain.

44. Would Health Canada commit to an immediate and independent investigation into the dangers posed by antenna farms and, should these show harm, would it commit to establishing biologically (health)-based exposure standards?

It is Health Canada’s scientific position that no adverse health effects associated with exposure of the general public to RF fields are anticipated, provided that exposure levels are below the limits outlined in Safety Code 6. Nevertheless, should any credible, independently replicated and consistent adverse health effect be demonstrated at RF field exposures below the limits outlined in Safety Code 6, Health Canada would initiate a revision of its exposure limits. Ensuring that human exposures do not exceed the human exposure limits outlined in Health Canada’s Safety Code 6 near antennas and/or antenna farms is the responsibility of Industry Canada.

45. Considering the improper procedures and equipment used in the 2001 testing for EMR on Triangle Mountain, why should the residents of Colwood have any confidence in Health Canada’s and Industry Canada’s assurances that they are safe since the actions of their employees left them in no position to offer an opinion?

Health Canada had no involvement in the testing of EMR on Triangle Mountain. Compliance of wireless transmitters is the responsibility of Industry Canada.

46. Given the lack of concern for the public demonstrated by their employees at every level, why should the citizens of Canada have confidence in anything Health Canada or Industry Canada says or does?

Health Canada is the federal department responsible for helping Canadians maintain and improve their health. This is a responsibility that all staff at Health Canada, including those involved in the health risk assessment of EMF, take seriously.

Health Canada conducts its own analysis of the scientific literature on EMF in a completely independent fashion. All research, review and surveillance activities in the area of bioelectromagnetics health risk assessment by Health Canada have been solely funded by the Government of Canada. Health Canada is not dependent on any external parties for its risk assessment of the safety of RF fields.

It is Health Canada’s scientific position that no adverse health effects associated with exposure of the general public to RF fields are anticipated, provided that exposure levels are below the limits outlined in Safety Code 6.

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Minister's Response: Industry Canada

29 January 2009

Mrs. Sharon and Mr. Denis Noble
818 Bexhill Place
Victoria, British Columbia V9C 3V5

Dear Mr. and Mrs. Noble:

I am writing to provide you with Industry Canada’s response to two Environmental Petitions, No. 255, received 25 June 2008, regarding the effects of non-thermal electromagnetic radiation at Triangle Mountain, Colwood, British Colombia, and Environmental Petition No. 255-B, received 21 July 2008, requesting that transmission towers be removed from there. These petitions were forwarded to the Minister of Health and the Minister of Industry by the Commissioner of the Environment and Sustainable Development. I am pleased to respond to your questions that fall within Industry Canada’s area of responsibility.

Environmental Petition No. 255

Question 3: Are Health Canada and Industry Canada employees required to sign conflict of interest statements that declare they have no affiliation with any organization that may bring into question the impartiality of their work?

Question 4: Are scientists conducting research for Health Canada and Industry Canada required to sign conflict of interest statements that declare they have no affiliation with any organization, nor do they accept, directly or indirectly, funding from any source that could be perceived in any way to cast doubt on the objectivity of their work?

Question 5: Do Industry Canada and Health Canada adhere to the rule that the authors, whatever their affiliation, of all studies that Industry Canada or Health Canada depend on to support their position on

(EMR), must clearly be seen to be independent, and must be willing to declare that they have no financial interests in the outcome of their studies and that they receive no industry funding, whether directly or indirectly, in carrying out their studies?

Question 13: How much has the telecommunications industry spent for research annually over the last 5 years?

Regarding the quantity of money spent by the telecommunications industry on research, Industry Canada does not maintain records of this nature.

Question 16: Will Health Canada and Industry Canada amend its public documents to reflect the fact that Canada’s standard is not consistent with most other developed countries and to instruct its researchers to stop telling the public that Canada’s standards are among the most stringent in the world?

Question 17: Health Canada and Industry Canada do not follow the stricter safety codes of most of Europe but rather the much more lax safety codes of the US. To what degree is this due to Health Canada and Industry Canada having been unduly influenced by the powerful North American telecommunication industry?

Question 18: Why do Health Canada and Industry Canada require that the risk be established before the precautionary principle is applied when the essential point of the Precautionary Principle is to provide protection in the absence of full scientific certainty?

Question 20: Until and unless the precautionary principle is implemented as intended, would Health Canada and Industry Canada amend their public statements so as to eliminate the possibility of confusing the public about the fact that they are employing risk management, not the precautionary principle?

Question 21: Have Industry Canada and Health Canada changed the label of their risk assessment approach (which emphasizes cost) to the “Precautionary Principle” (which emphasizes safety) in an attempt to co-opt the positive public opinion of the Precautionary Principle without having to change the focus of their approach?

Question 30: Given that these FM transmitters are in close proximity to and directed toward schools, and given that children are more susceptible to radiation danger, how will Health Canada and Industry Canada respond to concerns from parents about their children’s health?

Health Canada has established safety guidelines for exposure to radiofrequency fields in its Safety Code 6 publication entitled Limits of Human Exposure to Radiofrequency Electromagnetic Fields in the Frequency Range from 3 kHz to 300 GHz. To Industry Canada’s knowledge, Health Canada endorses the precautionary principle and its approach to decision making can be found on their website at http://www.hc-sc.gc.ca/sr-sr/advice-avis/decision/index-eng.php.

While the responsibility for developing Safety Code 6 rests with Health Canada, Industry Canada has adopted this guideline for the purpose of protecting the general public, which includes pregnant women, seniors, children, the chronically ill, and persons with disabilities.

Industry Canada requires that all proponents and operators ensure that their radiocommunication and broadcasting installations comply with Safety Code 6 at all times. Proponents and operators must also consider the combined effects of nearby installations within the local radio environment.

Industry Canada independently chose to adopt Safety Code 6 for the protection of the general public. This decision was not taken due to influence by the telecommunication industry.

To Industry Canada’s knowledge, Health Canada’s Safety Code 6 takes into account all possible biological and/or health effects of radiofrequency fields, including short-term heating, non-thermal and/or long-term effects. Furthermore, it has been determined that there is no convincing scientific evidence that exposure to radiofrequency fields at levels below the limits outlined in Safety Code 6 cause any adverse health effects.

Question 32: Who is responsible for establishing the parameters for technical analyses associated with multiples transmitters?

Question 34: How does Industry Canada ensure that the allowable limits for maximum values are never exceeded?

The technical aspects of radiocommunication, including the technical aspects of broadcasting, is under the responsibility of Industry Canada. It is the responsibility of proponents and operators of installations to ensure that all radiocommunication and broadcasting installations comply with Health Canada’s Safety Code 6 at all times, including consideration of combined effects of nearby installations within the local radio environment.

Compliance with Safety Code 6 is an ongoing obligation. Antenna system operators may be required, as directed by Industry Canada at any time, to demonstrate compliance with Safety Code 6 by (i) providing detailed calculations, and/or (ii) conducting site surveys and, where necessary, by implementing corrective measures.

Question 33: Do these “theoretical calculations” take into consideration the fundamental properties of EM fields, namely reflection and compounding?

Industry Canada’s internal tools that are used for assessing Safety Code 6 compliance take into account the fundamental properties of EM fields. Ground wave reflection of the electromagnetic waves, as well as the compounding of field strengths produced by all antenna systems, are taken into account when theoretical calculations are made to determine radio frequency (RF) exposure compliance. Numerous other electromagnetic properties of antennas, such as frequency, effective radiated power (ERP), antenna gain, antenna pattern, size of the antenna and antenna tilt, need to be accounted for during theoretical calculations, where appropriate and as required.

Question 36: Why is Industry Canada taking the approach of requiring the placement of multiple transmitters on towers?

Is it, as I have been told by Mr. Jim Laursen of Industry Canada, because people see the towers and complain; they don’t see the transmitters and don’t complain?

Question 38: Under the new siting policy, CPC-2-0-03, no consultation is required for placement of new transmitters, only for new towers. Why was this presented to the public as an effort for more consultation between Industry Canada and the public when it really was intended to allow the creation of antenna farms with no consultation with or input by the public?

Procedures for the installation of new towers are set out in Industry Canada’s Client Procedures Circular (CPC) 2-0-03, entitled Installing Radiocommunication and Broadcasting Antenna Systems, Issue 4, which replaces the former CPC-2-0-03, entitled Environmental Process, Radiofrequency Fields and Land-Use Consultation, Issue 3, 24 June 1995. In preparing its update to the procedures, the department studied the recommendations of both the Telecommunications Policy Review and the National Antenna Tower Policy Review. These reviews indicate that there are compelling social and economic reasons to support antenna tower and site sharing.

Industry Canada has incorporated many of the key recommendations of these two independent public reviews into the updated procedures, notably those relating to sharing and the exclusion from consultation for certain types of installations, while recognizing the requirement to balance the need for local input with the orderly development of radiocommunication in Canada. Local consultation regarding the installation of a new tower gives the public an opportunity to provide their input.

Question 41: Would Industry Canada provide the power level of each of the 55 transmitters within 2 kilometres of my home?

Publicly available licence information, including power levels, is available on Industry Canada’s Spectrum Direct website at https://sd.ic.gc.ca, which is updated regularly and therefore provides the most current information. One of the features of the website is a geographic search feature that permits search radii that can encompass all of Canada.

Question 42: Does Industry Canada have a limit to the number of transmitters that will be added within this radius?

No, Industry Canada does not have a preset limit on the number of transmitters for a given geographic area. However, there are a number of technical issues that may limit the number of transmitters in a given location. For example, Industry Canada applies Health Canada’s Safety Code 6 for the protection of the general public related to radiofrequency exposure. The field strength limits described in Safety Code 6, are not to be exceeded at any location accessible to the public.

Question 45: Considering the improper procedures and equipment used in the 2001 testing for EMR on Triangle Mountain, why should the residents of Colwood have any confidence in Health Canada’s and Industry Canada’s assurances that they are safe since the actions of their employees left them in no position to offer an opinion?

The department can assure the residents of Colwood that the employees who took measurements have proper training to work in the radio frequency discipline, have knowledge of electromagnetic field theory and followed proper engineering methods and practices. In 2001, the power density levels at Triangle Mountain were tested and Industry Canada staff found the levels to be in compliance with Safety Code 6 at all locations examined. The department has full confidence in the testing procedures and measurement equipment that were used to verify public Safety Code 6 compliance on Triangle Mountain in 2001 and, again, in 2008.

Question 46: Given the lack of concern for the public demonstrated by their employees at every level, why should the citizens of Canada have confidence in anything Health Canada or Industry Canada says or does?

Industry Canada employs competent and professional staff. Our employees are often called upon to find solutions for complex situations and, in doing so, may need to weigh competing interests with consideration of Industry Canada’s official mandate.

As can be expected in these types of complex situations, it may be necessary to make decisions that are not supported by the competing interests. Industry Canada employees would never knowingly place the health of the Canadian public at risk.

I appreciated this opportunity to respond to your petition, and trust this information is of assistance.

Yours sincerely,

[Original signed by Tony Clement, Minister of Industry]

Tony Clement

c.c. Mr. Scott Vaughan
Commissioner of the Environment and Sustainable Development