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23 September 2017

Canada: C4ST Submission to the Industry, Science and Economic Development (ISED) Public Consultation on 5G

C4ST Submission to the Industry, Science and Economic Development (ISED) public consultation on 5G
c4st.org, 15 September 2017

Click here to download pdf version of this letter

Innovation, Science and Economic Development Ottawa, ON
September 15, 2017

To: ic.spectrumauctions-encheresduspectre.ic@canada.ca

RE: Canada Gazette, Part I, June, 2017, “Consultation on Releasing Millimetre Wave Spectrum to Support 5G”, notice

reference number (SLPB- 001-17).

Dear Sir or Madame:

This submission is regarding the Canada Gazette, Part I, June, 2017, “Consultation on Releasing Millimetre Wave Spectrum to Support 5G”, notice reference number (SLPB- 001-17). Specifically question 7-2.

Canadians for Safe Technology (C4ST) is aware that Industry, Science and Economic Development (ISED) has adopted Health Canada’s Safety Code 6 guidelines as its standard for safe exposure of people to wireless radiation of the frequency bands under the proposed licensing. From past experiences, we know that Health Canada has been slow to act on other public health issues e.g. cigarette smoking, thalidomide and asbestos.

We believe it is prudent that ISED should implement a moratorium on the issuance of new licenses under the New Licensing Framework for the 24, 28 and 38 GHz Bands and request this moratorium be expanded to the 37-40 GHz and 64-71 GHz Bands for the following reasons:

1.  Many radiation emitting antennae within meters of homes and schools – Intensive infrastructure will be required because 5G technology is effective only over short distances, and is poorly transmitted through solids. This requires unobstructed paths between transmitters and receivers. Thus, many antennae are necessary, preferably line-of-sight. As a result, full-scale implementation could result in “small” yet powerful antennae every 3 to 10 houses in residential areas.1

2.  Concern regarding health effects – There is strong scientific evidence that the radiation we are now being exposed to from 2G, 3G and 4G has serious adverse effects on human health.2 The new spectrum proposed to be licensed has undergone very little research on human health effects. Neither Health Canada nor Innovation, Science and Economic Development Canada can point to any peer-reviewed evidence-based science that shows 5G technology is safe.3What we do know is of concern.
3. Cancer concerns – Radiation from wireless devices, including the 5G frequencies to be licensed, has been designated a Class 2B, possible human carcinogen by the World Health Organization.4 Lead is in the same category.

4.  Skin will be most affected – 5G radiation is chiefly absorbed by the skin, the largest organ of the body. 5, 6, 7, 8 The importance of an informed, precautionary approach is magnified due to interactions between wireless radiation and chemical toxicants9. As one example, some toxicants can concentrate in the skin, and interactions with wireless radiation may be one reason for increasing incidence of skin cancers on non-sun-exposed skin. 5G may magnify and accelerate this issue.

5.  Adverse effects demonstrated in military applications – We simply do not know the full effects of the 5G pulsed frequencies. As outlined by the Environmental Health Trust, we do know for frequencies just above 5G that“…the U.S., Russian and Chinese defense agencies have been developing weapons that rely on the capability of this electromagnetic frequency range to induce unpleasant burning sensations on the skin as a form of crowd control. Millimeter waves are utilized by the U.S. Army in crowd dispersal guns called Active Denial Systems10. This is exploiting the fact that sweat ducts may act as antennae for sub-millimetre wavelength radiation, that can cause point heating and pain.11

That these frequencies (millimetre wavelengths) have biological effects has been shown by trials of short term exposures for therapeutic treatments for neurological conditions.12 What we don’t know is what the health effects will be when people are exposed 24/7 from outside sources e.g. microcells on utility poles, as well as from inside sources from 5G emitting devices e.g. from household appliances.

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