I am a retired Government of Canada research biologist with over 30 years experience in original research projects including ten years in freshwater ecosystem toxicology. I fully support modernizing the Environmental Assessment processes to identify and include new environmental threats. A relevant example is that of anthropogenic electromagnetic fields - estimated to be millions of times above historical levels in many urban areas. Proper assessment data, including pre-project baseline data, should be conducted by an independent agency (not the proponent). Cumulative effects from multiple sources, as well as over time, should be monitored for undesirable effects e.g. the installation of wireless radiation emitting devices in close proximity (e.g. cellphone antennas, smart meters1 and 5G microcells).
The full potential adverse effects of EMFs on wildlife, and hence ecosystems, has not been taken into account by Canadian environmental legislation. This is a largely unstudied field2 . Human health is covered somewhat by Health Canada's Safety Code 6 which applies to federal workplaces and has been adopted by Innovation, Environment and Economic Development Canada in the regulation of wireless radiation devices. Other jurisdictions such as the Provinces, Territories and school boards have also adopted these guidelines. Undesirable effects below Safety Code 6 guidelines have been established in birds, insects and plants. An example is the disorientation in European robins exposed to ambient AM radiofrequency transmissions.
There is also some question as to whether EMFs may be a contributing factor in the world wide phenomenon of Colony Collapse Disorder in bees. For substantiating evidence of concerns about anthropogenic EMFs, attached is my recently submitted brief regarding the review of the Canadian Environmental Protection Act (CEPA). In summary 1. The Canadian Environmental Assessment process should allow for newly identified environmental threats to biota such as anthropogenic electromagnetic fields. 2. Proper baseline studies by an independent government body should be conducted before major installations go forward e.g. cell tower constructions, large scale roll outs of smart meters and deployment of 5G microcells. 3. Effective monitoring and reporting by an independent government agency for cumulative effects (concurrently and over time) is essential in the process to ensure minimal adverse effects.
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