Am Radio Rf Energy Assessment

OAKVILLE GREEN DEVELOPMENT – AM RADIO RF ENERGY ASSESSMENT

Stantec was asked to conduct a review of the Impact documents which were prepared by Whiteoaks consultants. The documents were commissioned to highlight impact of local land use proposals on the operation of the two existing AM radio stations, CJYE and CJMR. May 8, 2019

Prepared for:

Kenneth Poon, P.Eng. LEED AP; Civil Engineering Discipline Lead - Community Development

Prepared by:

Enzo D’Agostini P. Eng. Senior Telecommunications Engineer

Table of Contents

1.0 EXECUTIVE SUMMARY ...... I

2.0 BACKGROUND ...... 2.1

3.0 SAFETY CODE 6 – EXPOSURE LIMITS ...... 3.2 3.1 SPECIFIC ABSORPTION RATE LIMITS (SAR) (100 KHZ–6 GHZ) ...... 3.3

4.0 BASELINE PERSPECTIVE AND DISCUSSION ...... 4.5 4.1 REGULATORY CONSIDERATIONS (ISED) ...... 4.5 4.1.1 Radio Frequency Exposure Limits ...... 4.6

5.0 INITIAL CONDITIONS ...... 5.7 5.1 TECHNICAL DISCUSSION AND CONSIDERATIONS ...... 5.8 5.1.1 Free Space Path Loss, Attenuation of Electromagnetic Radio Waves ...... 5.9 5.1.2 Typical Directive Antenna Pattern Characteristics ...... 5.12 5.1.3 Internal Electrical Field Strength ...... 5.13 5.1.4 Signal Strength Calculations ...... 5.14 5.1.5 Induced and Contact Currents ...... 5.17 5.1.6 Magnetic Field Strength ...... 5.17 5.1.7 Re-Radiation Concerns ...... 5.18 5.1.8 Building Heights ...... 5.19

6.0 REFERENCES ...... 6.20

LIST OF TABLES Table 1 Key Observations and Conclusions ...... ii Table 2 Safety Code 6 - Internal Electric Field Strength Basic Restrictions (3 kHz-10 MHz) ...... 3.4 Table 3 Safety Code 6 - Specific Absorption Rate Basic Restrictions (100 kHz-6 GHz) ...... 3.4 Table 4 Safety Code 6 - Electric Field Strength Reference Levels ...... 3.5 Table 5 Safety Code 6 - Magnetic Field Strength Reference Levels ...... 3.5 Table 6 Free Space Path Loss Estimates ...... 5.9 Table 7 Location Prediction of Exposure Contours for AM Antenna Systems ...... 5.18

LIST OF FIGURES Figure 1 Free Space Path Loss Estimates ...... 5.10 Figure 2 Distance circle to Eastern edge of proposed development site ...... 5.10 Figure 3 Distance circle to Western edge (Third Line) of the proposed development site ...... 5.10 Figure 4 Proposed Plot Plan and site development ...... 5.11 Figure 5 Glenn Abbey Subdivision and other Buildings in close proximity of tower site ...... 5.11 Figure 6 Typical 2D Directive Antenna Power Pattern13 and CJMR/CJYE patterns1 ...... 5.12 Figure 7 Proof of Performance for CJMR and CJYE (Formerly CHWO) Radiation Patterns (1992) 1 ...... 5.13 Figure 8 Estimated Signal Strength (dBuV/m and V/m) for CJMR and CJYE signals at the Oakville Green Development Site using Free Space Loss Estimates...... 5.15

Figure 9 Estimated Signal Strength (dBuV/m and V/m) for CJMR and CJYE signals at the Oakville Green Development Site considering combined effect of co-sited non TDM operation...... 5.16

LIST OF APPENDICES

APPENDIX A ...... A.1 A.1 Safety Code 6, 2015 ...... A.1

APPENDIX B ...... B.1 A.2 EllisDon Letter, April 18, 2019 ...... B.1

APPENDIX C ...... C.1 A.3 Preliminary Proposed Building Elevations ...... C.1

APPENDIX D ...... D.1 A.4 Toronto AM Stations ...... D.1

1.0 EXECUTIVE SUMMARY

Stantec was asked to provide a professional opinion on concerns raised by Whiteoaks consultants in a document package entitled “Compressed_O'Connor MacLeod Hanna Comments_Redacted” 1. Within this document package there are numerous technical reports completed by Lawrence Behr Associates, Lehman and Associates and M.A. Tilston Engineering as well as a number of letters from private and public entities in support of the concerns raised by O’Connor MacLeod Hanna LLP.

The review of the document package included reports which highlighted concerns from human safety due to the potential for high levels of RF Energy predicted to be present at the proposed Oakville Green Development site. The reports also included in-depth calculations and modelling of various scenarios to show that the presence of the proposed four (4) fifteen (15) storey buildings at the site and their construction could have significant negative impact to the two (2) radio station’s licensed antenna radiation patterns. Various scenarios using different construction crane heights at close proximity to the tower site were presented to model the potential distortion to the licensed radiation contours.

The technical modelling, calculations and mathematical assessments in the report were completed using competent Electrical Engineering, valid antenna fundamentals knowledge and sound practices. There were however statements and calculations which were made out of context to raise concerns to a higher level. Specifically, that the investigated developments could introduce long term negative impact to the radio stations. The antenna array radiation pattern technical modelling was based on a different development proposal, “Martillac, Graydon-Banning and Oakville Green Life Sciences and Technology District.” 2 which was modelled to have residential components and tall structures within a few hundred meters of the Tower site.

The impact of the concluding statements regarding the Martillac, Graydon-Banning development are very different than those which would apply in the Oakville Green Development proposal due to the close proximity to the tower site. The modelling conclusions on the radiation pattern distortion caused has no direct relevance to the Oakville Green Development case. The models would need to be redone using appropriate distances and pertinent parameters based on detailed architectural plans for the Oakville Green Development and the radio station’s latest Proof of Performance submissions. There are sections in the document addressing re-radiation, building heights and contact currents by M.A. Tilston Engineering which go back to 1993. The modelling and conclusions in those sections are technically accurate but overly conservative given the latest RF energy limits in Safety Code 6. The modelling was done for other proposed developments and not specifically for the Oakville Green Development project.

i 1 - Compressed_O'Connor MacLeod Hanna Comments_Redacted, dated March 14, 2019 2 - Martillac, Graydon-Banning and Oakville Green Life Sciences and Technology District, extracted from Compressed_O'Connor MacLeod Hanna Comments_Redacted 3 – Safety Code 6 (2015); Limits of Human Exposure to Radiofrequency Electromagnetic Energy in the Frequency Range From 3 Khz TO 300 Ghz 4 – Lawrence Behr Associates extract from Compressed_O'Connor MacLeod Hanna Comments_Redacted 5 - TN-329 Technical Note; Safety Code 6 (SC6) Measurement Procedures (Uncontrolled Environment) 6 - TN-261, Issue 3, Safety Code 6 (SC6) Radio Frequency Exposure Evaluation Template (Uncontrolled Environment Exposure Limits), replaces TN- 261, Issue 2, published in December 2012. 7 - Federal Communications Commission (FCC) OET65 (http://www.fcc.gov/oet/info/documents/bulletins/) 8 - Broadcasting Procedures and Spectrum Management and Telecommunications, Part 2 - BPR-2 Issue 3, February 2016 9 - Letter from EllesDon Dated April 18, 2019

The specific focus of this review is on the human safety concerns which have been raised by Whiteoaks and their consultants several times in the past. Stantec has reviewed the various documents and has estimated the level of RF energy which is predicted to be present at the proposed Oakville Green Development site. Health Canada’s Safety Code 6 (2015)3 is the governing document which sets out the limits for human safety with respect to RF energy exposure and absorption by the human body.

Our calculation estimates are presented in this document and are based on worst-case scenarios. The assumptions we used for the calculations are based on antenna contours provided though the “Compressed_O'Connor MacLeod Hanna Comments_Redacted” 1 document package which is assumed to be fairly current and accurate. The key point to be made here is that the CJMR and CJYE licensed antenna radiation pattern is specifically designed to radiate maximum RF energy in the direction of it’s servicing area (North-West to North East direction) from Azimuth ~3150 to ~90 0 and to minimize interference to other AM stations in the region. The “Back-Lobe” direction which is relevant to the Oakville Green Development covers from approximately azimuth 1800 to 2700 (South to South-West direction). The focus of our review is based on the RF Energy which is radiated in the relevant Back Lobe direction.

Table 1 below summarizes the key observations and findings from our review and calculation estimates.

Table 1 Key Observations and Conclusions

Key Observations and Conclusions from our Review

Item Category Descriptive

1.0 Transmitter • The Radio Stations licensed transmitter power levels have been Power reduced to 10 kW from the worst case 20 kW used in the calculations back in 2009. This suggests that the RF energy levels at the Oakville Green Development site will be at a reduced level. Comparatively speaking, for CJMR, a reduction of as much as 50% with reference to the Halton Hospital calculations done in 2009.

2.0 Antenna • The antenna array radiation pattern at the tower site was designed Radiation to optimize and maximize transmitter power in the direction of it’s Pattern licensed servicing area but also for interference protection of other Radio stations in the region. The radiation pattern design contains a

ii 1 - Compressed_O'Connor MacLeod Hanna Comments_Redacted, dated March 14, 2019 2 - Martillac, Graydon-Banning and Oakville Green Life Sciences and Technology District, extracted from Compressed_O'Connor MacLeod Hanna Comments_Redacted 3 – Safety Code 6 (2015); Limits of Human Exposure to Radiofrequency Electromagnetic Energy in the Frequency Range From 3 Khz TO 300 Ghz 4 – Lawrence Behr Associates extract from Compressed_O'Connor MacLeod Hanna Comments_Redacted 5 - TN-329 Technical Note; Safety Code 6 (SC6) Measurement Procedures (Uncontrolled Environment) 6 - TN-261, Issue 3, Safety Code 6 (SC6) Radio Frequency Exposure Evaluation Template (Uncontrolled Environment Exposure Limits), replaces TN- 261, Issue 2, published in December 2012. 7 - Federal Communications Commission (FCC) OET65 (http://www.fcc.gov/oet/info/documents/bulletins/) 8 - Broadcasting Procedures and Spectrum Management and Telecommunications, Part 2 - BPR-2 Issue 3, February 2016 9 - Letter from EllesDon Dated April 18, 2019

“Back Lobe” to limit the amount of power in the opposite direction of the main lobe. Effectively, the transmitter power is reduced considerably in this back direction from the main lobe power. The polar plots of the existing antenna patterns for both CJMR and CJYE indicate that the “Back Lobe” power is reduced from ~15 dB to ~20 dB from that of the main lobe. That suggests that in the direction of the proposed Oakville Green development (~180 degrees from the radiation pattern main lobe), the transmitter appears to behave more like a 300 watt (0.3 kW) transmitter.

3.0 Safety Code 6 • Our calculation estimates were done assuming the “Back Lobe” Impact power at three (3) different levels. Specifically, at Full power (0 dB), Calculation and at reduced Back Lobe power (-15 dB and -18 dB) based on the Estimates Polar Plots presented in the Lawrence Behr Associates (LBA)4 report section.

4.0 Calculation • Electric Field Strength; Our calculation estimates show that worst- Estimate case Electrical Field Strength predicted to be present at the Results proposed Oakville Green Development site will only approach ~1% (0.704 V/m RMS) of the Safety Code 6 limits. This level is far from the 50% guideline (37.8 V/m RMS) which would raise concern to the point that the operator(s) of radio frequency emitters must notify ISED and demonstrate compliance with Safety Code 6. From this review and to our knowledge, this mandatory notification has not occurred. If it had, why would it not be included in the reports along with measured values to substantiate Safety Code 6 compliance?

• Induced Currents; TN-329 Technical Note; “Safety Code 6 (SC6) Measurement Procedures (Uncontrolled Environment) 5” suggests that these conditions “may occur” when the electric field strength is as low as 25% of the Safety Code 6 exposure limit. In the Oakville Development case, the Electrical Field Strength is substantially below the 25% figure however from the M.A. Tilston Engineering report section on contact currents, there is concern around the construction site where the potential for the “startle effect” to trigger

iii 1 - Compressed_O'Connor MacLeod Hanna Comments_Redacted, dated March 14, 2019 2 - Martillac, Graydon-Banning and Oakville Green Life Sciences and Technology District, extracted from Compressed_O'Connor MacLeod Hanna Comments_Redacted 3 – Safety Code 6 (2015); Limits of Human Exposure to Radiofrequency Electromagnetic Energy in the Frequency Range From 3 Khz TO 300 Ghz 4 – Lawrence Behr Associates extract from Compressed_O'Connor MacLeod Hanna Comments_Redacted 5 - TN-329 Technical Note; Safety Code 6 (SC6) Measurement Procedures (Uncontrolled Environment) 6 - TN-261, Issue 3, Safety Code 6 (SC6) Radio Frequency Exposure Evaluation Template (Uncontrolled Environment Exposure Limits), replaces TN- 261, Issue 2, published in December 2012. 7 - Federal Communications Commission (FCC) OET65 (http://www.fcc.gov/oet/info/documents/bulletins/) 8 - Broadcasting Procedures and Spectrum Management and Telecommunications, Part 2 - BPR-2 Issue 3, February 2016 9 - Letter from EllesDon Dated April 18, 2019

an accident could occur with Electrical Field strengths much lower than the 25%. There are mitigation strategies which can be undertaken during the construction phase to reduce and/or eliminate the “startle effect” concerns.

• Magnetic Field Strength; The Magnetic Field Strengths of various AM Radio station Transmitters and their predicted safe distances from the base of the towers are shown in Table 7 which was extracted from FCC OET Bulletin 654 6. It is readily seen from this Table that exposure contours for a 10 kW transmitter fall off below 25 V/m (0.06 A/m) within a distance of only 60 meters from the tower base.

• The Oakville Green Development site boundary, which is in the antenna array’s “far-field” is in the worst-case 490 meters away from the towers. The main area of the site development is concentrated at ~800 meters from the tower site. We can confidently conclude that Safety Code 6 Limits for Magnetic Field Strength (0.73/f A/m RMS; 0.41 A/m RMS) will not be violated within the proposed site. Human safety concerns are most significant within the antenna Array’s “Near Field” boundary and are generally contained within the physical boundary of the tower site. This statement is in agreement with M.A. Tilston Engineering in their technical report, “A General Procedure To Compute Contour Maps Near AM Broadcast Stations For (1) Safe Building Heights To Avoid Excessive AM Broadcast Reradiatioon And Human Health Hazard, And (2) Zones Of Interference To Radio-Sensitive Equipment”1 , section 6 Summary which states, “It was shown that under normal circumstances described herein, it can be assumed that the limits on exposure to electric and magnetic fields will not be exceeded outside the boundaries of an AM broadcast transmitter site”.

5.0 Re-Radiation • It is important to note that the re-radiation impact cannot be accurately predicted with certainty as there are many variables and factors which must be considered. The modelling and calculation estimates in the LBA report 4 were made “based on arbitrary

iv 1 - Compressed_O'Connor MacLeod Hanna Comments_Redacted, dated March 14, 2019 2 - Martillac, Graydon-Banning and Oakville Green Life Sciences and Technology District, extracted from Compressed_O'Connor MacLeod Hanna Comments_Redacted 3 – Safety Code 6 (2015); Limits of Human Exposure to Radiofrequency Electromagnetic Energy in the Frequency Range From 3 Khz TO 300 Ghz 4 – Lawrence Behr Associates extract from Compressed_O'Connor MacLeod Hanna Comments_Redacted 5 - TN-329 Technical Note; Safety Code 6 (SC6) Measurement Procedures (Uncontrolled Environment) 6 - TN-261, Issue 3, Safety Code 6 (SC6) Radio Frequency Exposure Evaluation Template (Uncontrolled Environment Exposure Limits), replaces TN- 261, Issue 2, published in December 2012. 7 - Federal Communications Commission (FCC) OET65 (http://www.fcc.gov/oet/info/documents/bulletins/) 8 - Broadcasting Procedures and Spectrum Management and Telecommunications, Part 2 - BPR-2 Issue 3, February 2016 9 - Letter from EllesDon Dated April 18, 2019

modelling configurations of building shape, crane geometry and placement at average and extreme locations”4. Also, these were specifically completed for the Graydon Banning and Martillac project which is NOT part of the proposed Oakville Green Development project. The distances from the transmitter site which were used ranged from 100m to 300m where calculated signal strength would be greater than 1.0V/m. In our opinion, where the Field Strengths are less than 1% of the Safety Code 6 limits and well below 1V/m RMS, signal re-radiation concerns from a Human Safety perspective are not considered an issue at this development site. Whether or not there will be a significant impact to the Radio station licensed antenna contours is outside the scope of this review.

• Further, it is important to note that there are several AM Radio Stations in downtown Toronto which continue to operate at power levels similar to or greater than CJMR and CJYE. Some of these stations are literally less than a few hundred meters away from adjacent occupied high-rise buildings. The operators would not be allowed to continue operations if there were any Safety Code 6 human safety concerns in the immediate proximity of the station antenna arrays. Please refer to the Toronto AM Radio station overlays in Appendix D.

6.0 Tower Site • According to “Broadcasting Procedures and Spectrum Management Owner and Telecommunications, Part 2" - BPR-2 Issue 3, February 2016 7, Obligations it is the responsibility of proponents and operators of installations to ensure that “…all radio communication and broadcasting installations comply with Safety Code 6 at all times, including the consideration of combined effects of nearby installations within the local radio environment…”

• Compliance with Safety Code 6 is an ongoing obligation. At any time, antenna system operators may be required, as directed by ISED, to demonstrate compliance with Safety Code 6 by (i)

v 1 - Compressed_O'Connor MacLeod Hanna Comments_Redacted, dated March 14, 2019 2 - Martillac, Graydon-Banning and Oakville Green Life Sciences and Technology District, extracted from Compressed_O'Connor MacLeod Hanna Comments_Redacted 3 – Safety Code 6 (2015); Limits of Human Exposure to Radiofrequency Electromagnetic Energy in the Frequency Range From 3 Khz TO 300 Ghz 4 – Lawrence Behr Associates extract from Compressed_O'Connor MacLeod Hanna Comments_Redacted 5 - TN-329 Technical Note; Safety Code 6 (SC6) Measurement Procedures (Uncontrolled Environment) 6 - TN-261, Issue 3, Safety Code 6 (SC6) Radio Frequency Exposure Evaluation Template (Uncontrolled Environment Exposure Limits), replaces TN- 261, Issue 2, published in December 2012. 7 - Federal Communications Commission (FCC) OET65 (http://www.fcc.gov/oet/info/documents/bulletins/) 8 - Broadcasting Procedures and Spectrum Management and Telecommunications, Part 2 - BPR-2 Issue 3, February 2016 9 - Letter from EllesDon Dated April 18, 2019

providing detailed calculations, and/or (ii) conducting site surveys and, where necessary, by implementing corrective measures.

• Where the radio frequency emission of any installation, whether telecommunications carrier or broadcasting operator, is greater than, or is equal to, 50%, of the Safety Code 6 limits for uncontrolled environments at locations accessible to the general public (i.e. not solely available for access by workers), the operator(s) of radio frequency emitters must notify ISED and demonstrate compliance with Safety Code 6.

7.0 Halton Hospital • To our knowledge, no issues with human safety from the AM radio Project (2009) station RF energy exposure at the site were encountered or reported throughout the construction and at any time after the Halton Hospital was operational. It’s now greater than eight (8) years after the construction. If there were any human safety problems, we would certainly have heard about them by now. The attached letter from EllisDon Dated April 18, 2019 8 states their experience pre and post construction of the Hospital site.

• If there were any significant distortions or negative impacts to the radio station licensed radiation patterns, from the construction and ongoing operations at the Halton Hospital site, there should be evidence that corrective action was taken by the tower site operators to bring the radiation pattern back into licensed compliance. No formal data appears to exist to support this and no supporting data was included in the “Compressed_O'Connor MacLeod Hanna Comments_Redacted”1 document package.

• Further, in our opinion, it would have been prudent for the two radio station owners to conduct field surveys before and after the Hospital was constructed in order to make a strong case to substantiate their concerns. To our knowledge, this was not done, and no supporting data was included in the “Compressed_O'Connor MacLeod Hanna Comments_Redacted”1 document package.

vi 1 - Compressed_O'Connor MacLeod Hanna Comments_Redacted, dated March 14, 2019 2 - Martillac, Graydon-Banning and Oakville Green Life Sciences and Technology District, extracted from Compressed_O'Connor MacLeod Hanna Comments_Redacted 3 – Safety Code 6 (2015); Limits of Human Exposure to Radiofrequency Electromagnetic Energy in the Frequency Range From 3 Khz TO 300 Ghz 4 – Lawrence Behr Associates extract from Compressed_O'Connor MacLeod Hanna Comments_Redacted 5 - TN-329 Technical Note; Safety Code 6 (SC6) Measurement Procedures (Uncontrolled Environment) 6 - TN-261, Issue 3, Safety Code 6 (SC6) Radio Frequency Exposure Evaluation Template (Uncontrolled Environment Exposure Limits), replaces TN- 261, Issue 2, published in December 2012. 7 - Federal Communications Commission (FCC) OET65 (http://www.fcc.gov/oet/info/documents/bulletins/) 8 - Broadcasting Procedures and Spectrum Management and Telecommunications, Part 2 - BPR-2 Issue 3, February 2016 9 - Letter from EllesDon Dated April 18, 2019

8.0 Surrounding • The Glenn Abbey residential subdivision is located just South and Sub-Division South-West of Dundas Street across from the Tower site. It is South of literally less than 300 meters from the site. There is also St Dundas Street Volodymyr Cultural Centre and West Preschool Centre located directly across Dundas Street from the tower site, less than 250m from the antennas.

• If RF energy levels exceeding Safety Code 6 limits are present within these two locations, the tower owners must notify ISED and demonstrate compliance with Safety Code 6. This must have taken place and we are either not aware of it, or even at this 300m distance, Safety Code 6 limits are NOT violated. Our calculation estimates predict that at 300m distance, in the “Back-Lobe” direction, Electrical Field Strength in the worst-case would only approach ~2.1% (1.6V/m RMS) of the Safety Code 6 limits.

Overall, from our review and analysis, we are confident that the proposed Oakville Green Development site will not have significant and alarming levels of RF energy reaching it from the radio station tower site which is located from ~490m, nearest boundary point to ~870m, the furthest boundary point from the site. By significant, we are suggesting that we predict that less than 1% of the Safety Code 6 limits for human safety exposure will be reached at the site. Actual field measurements would be required to validate the predicted results given the many unknowns that exist, however even if the calculation estimates are overly conservative by a factor of 50% or more, the results would still fall well within 1%-2% of the limits of Safety Code 6.

It is prudent however to further investigate the potential impact that the four (4) proposed fifteen (15) storey structures will have on the Radio station’s licensed radiation pattern and to the contact currents at the actual building locations. Once detailed design is completed, and site building geometry and heights are finalized, technical modelling of the buildings impact to the radio station licensed radiation pattern should be completed. Distortion of the radiation pattern through signal reradiation, could add substantially to the received Electrical field strength at the proposed site and place the Radio Stations out of licensed compliance.

vii 1 - Compressed_O'Connor MacLeod Hanna Comments_Redacted, dated March 14, 2019 2 - Martillac, Graydon-Banning and Oakville Green Life Sciences and Technology District, extracted from Compressed_O'Connor MacLeod Hanna Comments_Redacted 3 – Safety Code 6 (2015); Limits of Human Exposure to Radiofrequency Electromagnetic Energy in the Frequency Range From 3 Khz TO 300 Ghz 4 – Lawrence Behr Associates extract from Compressed_O'Connor MacLeod Hanna Comments_Redacted 5 - TN-329 Technical Note; Safety Code 6 (SC6) Measurement Procedures (Uncontrolled Environment) 6 - TN-261, Issue 3, Safety Code 6 (SC6) Radio Frequency Exposure Evaluation Template (Uncontrolled Environment Exposure Limits), replaces TN- 261, Issue 2, published in December 2012. 7 - Federal Communications Commission (FCC) OET65 (http://www.fcc.gov/oet/info/documents/bulletins/) 8 - Broadcasting Procedures and Spectrum Management and Telecommunications, Part 2 - BPR-2 Issue 3, February 2016 9 - Letter from EllesDon Dated April 18, 2019

Although, we can confidently conclude that contact currents will not violate the Safety Code 6 limits at the site distance, it is recommended that mitigation strategies be considered during the construction phase since even with these lower levels of Field Strength, there is always a possibility of “startle effect” impact.

Rooftop metallic objects and structures and construction site machinery such as vertical cranes, hoisting cables, lamp or lighting poles and other susceptible metallic objects which approach one-quarter (1/4) wavelength (~60 m) or less in length could develop induced contact currents sufficient to startle a worker and create an unsafe situation.

These concerns can be mitigated by taking appropriate action and safety measures to minimize the induced current impact. Appropriate PPE such as rubber gloves and rubber soled (electrically insulated) work boots and other appropriate personal protection equipment should be considered. Appropriate actions could also include conducting some actual field and rooftop measurements on site once the buildings are completed and then deciding on the best mitigation strategy.

viii 1 - Compressed_O'Connor MacLeod Hanna Comments_Redacted, dated March 14, 2019 2 - Martillac, Graydon-Banning and Oakville Green Life Sciences and Technology District, extracted from Compressed_O'Connor MacLeod Hanna Comments_Redacted 3 – Safety Code 6 (2015); Limits of Human Exposure to Radiofrequency Electromagnetic Energy in the Frequency Range From 3 Khz TO 300 Ghz 4 – Lawrence Behr Associates extract from Compressed_O'Connor MacLeod Hanna Comments_Redacted 5 - TN-329 Technical Note; Safety Code 6 (SC6) Measurement Procedures (Uncontrolled Environment) 6 - TN-261, Issue 3, Safety Code 6 (SC6) Radio Frequency Exposure Evaluation Template (Uncontrolled Environment Exposure Limits), replaces TN- 261, Issue 2, published in December 2012. 7 - Federal Communications Commission (FCC) OET65 (http://www.fcc.gov/oet/info/documents/bulletins/) 8 - Broadcasting Procedures and Spectrum Management and Telecommunications, Part 2 - BPR-2 Issue 3, February 2016 9 - Letter from EllesDon Dated April 18, 2019 OAKVILLE GREEN DEVELOPMENT – AM RADIO RF ENERGY ASSESSMENT

Executive Summary May 8, 2019

Abbreviations

AM Amplitude Modulation

ERP Effective Radiated Power

FSPL Free Space Path Loss

ISED Innovation, Science and Economic Development

NS Nerve stimulation

OMB Ontario Municipal Board

PPE Personal Protection Equipment

RF Radio Frequency

SAR Specific Absorption Rate

SC6 Safety Code 6

TDM Time Division Multiplex

OAKVILLE GREEN DEVELOPMENT – AM RADIO RF ENERGY ASSESSMENT

Background May 8, 2019

2.0 BACKGROUND

Stantec was asked to review and assess concerns raised by Whiteoaks Communications Group Ltd. (Whiteoaks) in respect of the proposed Oakville Green Development located near Dundas Street and Third Line in Oakville, ON.

The documents were commissioned by the radio stations in order to review the impact of local land use proposals on the operation of the two existing AM radio stations, CJYE and CJMR and their station transmitters located approximately 750 meters from the proposed new Oakville Green Development project to be located across the road to the North East of the Halton Healthcare Services Hospital site which was constructed approximately eight (8) years ago. The general conclusions in the documents are in support of land use controls to help protect the integrity of the radio station signals and their licensed antenna radiation patterns in order to maximize their market reach but also to ensure that land developments are not situated too close to the transmitters which could raise safety concerns for the construction workers during construction and the building tenants and occupants after construction.

The various documents contained significant sections on educating the reader on the nature of AM Radio Signals and how their transmission and propagation is impacted by metallic obstructions which can alter the intended signal path and cause unwanted reflection and re-radiation of the signal. This phenomenon can have negative impacts on the quality of the signals reaching the station’s intended customer base and could also cause unwanted interference to other radio station subscribers in other markets. Further, depending on the level of Radio Frequency (RF) energy, there could also be human safety concerns with touch potential or contact currents from metallic objects or structures. This report specifically focuses on the concerns raised regarding human safety in the proximity of the tower site.

The Compressed_O'Connor MacLeod Hanna Comments_Redacted_document1 also includes sections which are intended to provide guidance and recommendations on land use impacts such as minimum separation distances from the transmitters and building height restrictions to limit the possibility of signal blockage, signal re-radiation and to ensure human safety. The document includes mathematical calculations to predict primary interference contours based on the proposed antenna pattern design and transmitter operating power for the two stations. The intent of the interference contour is to provide guidelines for what minimum distances and building heights should be adhered to in order to ensure safe distances from high transmitter powers but also to ensure that buildings and developments are not going to interfere with the intended antenna patterns for maximum market coverage and licensing compliance.

The bottom line for this review is that there are three pertinent considerations that are relevant to this discussion and they include the following:

1) The primary consideration is on the safety of citizens working or living near RF energy sources, in this case specifically working within the Oakville Green Development site during the construction phases and ultimately ongoing exposure as patients, visitors and daily workers in the facility once it is operational.

2) Secondly, the potential impact on re-radiation that the proposed site buildings and their height may have to other licensed AM stations in the region. It is important to note that the re-radiation

10 - ISED publication entitles; CPC-2-0-03 — Radiocommunication and Broadcasting Antenna Systems 11 - ISED publication entitled; Canadian Municipalities and the Regulation of Radio Antennae and their Support Structures 12 - GL01-Issue 3; Guidelines for the Measurement of Radio Frequency Fields at Frequencies From 3 kHz to 300 GHz 13 - Fundamental Antenna Parameters: by Prof. Natalia K. Nikolova, McMaster University 14 - Lehman and Associates, M.A. Tilston Engineering, February 1993 15 - CPC-2-0-03 — Radiocommunication and Broadcasting Antenna Systems, ISED Publication 2.1

OAKVILLE GREEN DEVELOPMENT – AM RADIO RF ENERGY ASSESSMENT

Safety Code 6 – Exposure Limits May 8, 2019

impact cannot be accurately predicted with certainty as there are many variables and factors which must be considered. We will provide comments and our opinion on why we believe this impact will be minimal from a human safety perspective. The impact that re-radiation may have on the licensed antenna radiation pattern of the two radio stations is a different issue and at this time is outside the scope of this review and discussion.

3) Ensuring that electrical/electronic equipment used by the Health Care facilities on the site, which could have sensitivity to electromagnetic signal interference is either protected through noise immunity circuitry/strategies or the equipment is maintained at a safe distance from the RF energy source to ensure its proper operation. These concerns are not in scope for this specific review and discussion and will not be covered in this document.

Stantec will provide an engineering opinion on whether there are any issues or concerns raised relative to point #1 and #2 above, which the Oakville Green Developers and Land use authorities should address as part of the proposed project. If legitimate human safety issues or concerns surface from this review, recommendations on potential strategies and actions needed in order to mitigate or remove the concerns for those affected will be recommended.

3.0 SAFETY CODE 6 – EXPOSURE LIMITS

The exposure limits in Safety Code 6 are based upon the lowest exposure level at which any scientifically established adverse health effect occurs. Safety margins have been incorporated into the exposure limits to ensure that even worst-case exposures remain far below the threshold for harm. The scientific approach used to establish the exposure limits in Safety Code 6 is comparable to that employed by other science-based international standards bodies.

With respect to the first consideration, there are Government guidelines throughout the world which provide guidance in establishing safe limits for humans working or living around RF energy sources. In Canada, this guideline (99–EHD–237) was first published in 1999. A later revision in 2009, (Official document is HC Pub:091029) replaced the previous version of the Safety Code published in 1999 and became commonly known as “Safety Code 6” (Official document is HC Pub:091029) and its purpose is summarized below:

1) Specify maximum levels of human exposure to RF energy at frequencies between 3 kHz and 300 GHz, to prevent adverse human health effects;

2) Specify maximum allowable RF contact and induced body currents to prevent the physical perception of internal currents resulting from RF energy in uncontrolled environments, and to prevent RF shock or burns to personnel in controlled environments;

3) Provide guidance for evaluating RF exposure levels, to ensure that personnel in controlled and uncontrolled environments are not exposed to levels greater than the limits specified in the code.

The latest Safety Code 6 guideline was updated in 2015 and its purpose is to specify maximum levels of human exposure to RF fields at frequencies between 3 kHz and 300 GHz, to prevent adverse human

OAKVILLE GREEN DEVELOPMENT – AM RADIO RF ENERGY ASSESSMENT

Safety Code 6 – Exposure Limits May 8, 2019 health effects in both controlled and uncontrolled environments. The latest code is more refined and more aggressive in setting limits to RF exposure and how those limits are to be measured.

In the latest 2015 code, controlled environments are defined as those where all of the following conditions are satisfied:

(a) the RF field intensities in the controlled area have been adequately characterized by means of measurements or calculation,

(b) the exposure is incurred by persons who are aware of the potential for RF exposure and are cognizant of the intensity of the RF fields in their environment and,

(c) the exposure is incurred by persons who are aware of the potential health risks associated with RF field exposures and can control their risk using mitigation strategies.

All other situations that do not meet the specifications above are considered to be “uncontrolled” environments. Uncontrolled environments are defined as areas where either insufficient assessment of RF fields has been conducted or where persons who are allowed access to these areas have not received proper RF field awareness/safety training and have no means to assess or, if required, to mitigate their exposure to RF fields.

Uncontrolled environments have much more aggressive standards and limits. Safety Code 6 also specifies reference levels in the 3 kHz to 110 MHz frequency range, in terms of induced- or contact- currents (mA), for the avoidance of perception nerve stimulation (NS), shocks or burns.

While the biological basis for the basic restrictions specified in the Safety Code has not changed since the previous version (2009), the reference levels have been updated to either account for radiation absorption dosage refinements in recent years or where feasible, to harmonize with those of ICNIRP (10–11).

3.1 SPECIFIC ABSORPTION RATE LIMITS (SAR) (100 KHZ–6 GHZ)

From Safety Code 6, “The SAR is a measure of the rate at which electromagnetic energy is absorbed in the body. Basic restrictions for SAR are intended to prevent the occurrence of thermal effects from RF energy exposure on the body. At frequencies between 100 kHz and 6 GHz, the SAR limits (Table 3) take precedence over field strength and power density reference levels and shall not be exceeded.

The SAR should be determined for situations where exposures occur at a distance of 0.2 m or less from the source. In all cases, the values in Table 3 shall not be exceeded. For conditions where SAR determination is impractical, external unperturbed field strength or power density measurements shall be carried out and the limits outlined shall be respected.”

The code describes in considerable depth, the impact that RF energy exposure and thermal effects can have on human tissues as well as impacting the nervous system. Those details are accessible in the latest Safety Code 6 which has been included in Appendix A. Essentially, there are four (4) main

OAKVILLE GREEN DEVELOPMENT – AM RADIO RF ENERGY ASSESSMENT

Safety Code 6 – Exposure Limits May 8, 2019 categories of human safety concern that the new code addresses and are pertinent and apply to this study. Specifically;

1) Internal Electric Field Strength 2) Specific Absorption Rate (SAR) Basic Restrictions 3) Electrical Field Strength Reference Levels 4) Magnetic Field Strength Reference Levels

The following Tables have been extracted from Safety Code 6 and they establish the RF energy exposure requirements:

Table 2 Safety Code 6 - Internal Electric Field Strength Basic Restrictions (3 kHz-10 MHz)

Table 3 Safety Code 6 - Specific Absorption Rate Basic Restrictions (100 kHz-6 GHz)

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Table 4 Safety Code 6 - Electric Field Strength Reference Levels

Table 5 Safety Code 6 - Magnetic Field Strength Reference Levels

4.0 BASELINE PERSPECTIVE AND DISCUSSION

4.1 REGULATORY CONSIDERATIONS (ISED)

The following excerpts from Innovation, Science and Economic Development (ISED), formerly Industry Canada’s “CPC-2-0-03 — Radiocommunication and Broadcasting Antenna Systems 9” clearly outlines that it is the responsibility of the radio station tower owners to demonstrate compliance to Safety Code 6. This a strict requirement for all new antenna installations. Further, antenna owner operators can be directed by Industry Canada at any time, to demonstrate compliance with Safety Code 6 by;

1) providing detailed calculations, and/or 2) conducting site surveys and, where necessary, by implementing corrective measures.

It is clear that the obligation falls on the operator to demonstrate compliance. In this case, we are not sure that any actual field surveys were conducted to ascertain that there is a Safety Code 6 issue at the proposed location of the Oakville Green Development.

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Detailed calculations and signal pattern modelling are intended for new installations where a proponent is seeking a radio broadcast license and there is no way to complete field surveys before the antenna array is installed. In our case, some of the information provided in the documents goes back to the 1990’s and as such it is appropriate to request that actual field measurements be done under current operating conditions.

Further, there were concerns by the radio station owners when the Halton Hospital Development was being proposed. At that time, it would have been prudent to conduct field surveys before and after the Hospital was constructed in order to substantiate the safety concerns. To our knowledge, this was not done, and no issues with human safety related to absorption of RF energy were encountered or reported throughout the construction and at any time after the hospital was operational. The attached letter in Appendix B from EllisDon Dated April 18, 2019 8 indicates their experience with pre and post construction of the Hospital facility.

The CJYE and CJMR owners in the past have challenged the land use planning jurisdiction, the Ontario Municipal Board (OMB) by putting forward similar claims that their radio signal was going to be disrupted by proposed developments in the Oakville region. However, the evidence which they presented was ruled out of order at that time. All that was required was a simple field survey to substantiate the concerns by presenting the actual measurements. The excerpt below was extracted from an ISED publication entitled “Canadian Municipalities and the Regulation of Radio Antennae and their Support Structures 10”.

• “…While the issue is not truly within the scope of this study, it should be noted that, on occasion, those who own and operate radio antennae have complained that municipal planning has been undertaken without sufficient regard to the impact the local authorization process will have upon the operative capacity of the existing radio facility. As will be explained within this project (infra p. 7) some radio facilities are quite vulnerable to future development which can disrupt or obstruct radio signals. When such has occurred in the past, municipal officials have not been sensitive to the plight of the radio operator. For example, when the Ontario Municipal Board (OMB) was holding public hearings on extensive changes to the official plan for the City of Oakville, Ontario the existing AM radio broadcasting facility (CJYE Radio Station and CJMR Community Broadcasting) attempted to tender evidence about the resulting disruption to their signal, but their evidence was ruled out of order. The OMB chairman stated that only land use planning issues would be considered. The general facts surrounding the amendment of Oakville's official plan can be found in, Re Oakville Planning Area Official Plan, Amendments 28, 31 and 32 (1979), 9 O.M.B.R. 412….”

ISED establishes the requirements for the establishment, licensing and ongoing operations of AM Radio stations in it’s “Broadcasting Procedures and Spectrum Management and Telecommunications, Part 2" - BPR-2 Issue 3, February 2016 7.

4.1.1 Radio Frequency Exposure Limits

From the regulatory perspective, Health Canada has established safety guidelines for exposure to radio frequency 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”, Safety Code 6 (2015)3.

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Initial Conditions May 8, 2019

While the responsibility for developing Safety Code 6 rests with Health Canada, ISED has adopted this guideline for the purpose of protecting the general public. Current biomedical studies in Canada and other countries indicate that there is no scientific or medical evidence that a person will experience adverse health effects from exposure to radio frequency fields, provided that the installation complies with Safety Code 6. The following excerpt is from CPC-2-0-03 — Radiocommunication and Broadcasting Antenna Systems 15 and clearly outlines the owner responsibilities.

“…It is the responsibility of proponents and operators of installations to ensure that all radiocommunication and broadcasting installations comply with Safety Code 6 at all times, including the consideration of combined effects of nearby installations within the local radio environment.

Telecommunications common carriers and operators of broadcasting undertakings are to carry out an exposure evaluation on all new installations and following any increases in radiated power. Either measurement surveys or mathematical or numerical computations can be used for this evaluation. Where the radio frequency emission of any installation, whether telecommunications carrier or broadcasting operator, is greater than, or is equal to, 50%, of the Safety Code 6 limits for uncontrolled environments at locations accessible to the general public (i.e. not solely available for access by workers), the operator(s) of radio frequency emitters must notify ISED and demonstrate compliance with Safety Code 6. This determination of 50% of Safety Code 6 must be in consideration of the local radio environment.

For all proponents following ISED’s Default Public Consultation Process, the proponent's notification package must provide a written attestation that there will be compliance with Safety Code 6 for the protection of the general public, including consideration of nearby radiocommunication systems. The notification package must also indicate any Safety Code 6 related signage and access control mechanisms that may be used.

Compliance with Safety Code 6 is an ongoing obligation. At any time, antenna system operators may be required, as directed by ISED, 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. At the request of ISED, telecommunications carriers and operators of broadcasting undertakings must provide detailed compliance information for individual installations within five days of the request. Proponents and operators of existing antenna systems must retain copies of all information related to Safety Code 6 compliance such as analyses and measurements…” 5.0 INITIAL CONDITIONS

The following statements highlight the conditions which this review must consider to effectively evaluate the potential concerns raised by the Whiteoaks consultants. The situation today is considerably different than the initial conditions dealt with in Halton Hospital development case back in 2009. The following considerations apply:

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Initial Conditions May 8, 2019

• The proposed Oakville Green Development will be physically closer to the tower site than the Halton Hospital development. This suggests that the RF energy from the towers will arrive with a higher energy level than in the Halton Hospital case.

• There are four (4) proposed high rise building structures in the Oakville Green Development plot plan footprint. These are large structures and can have a much greater impact on the Radio Stations than the eight (8) story Halton Hospital structure.

• The Radio Station licensed transmitter power levels have been reduced to 10 kW from the worst case 20kW used in the calculations back in 2009. This suggests that the RF energy levels at the Oakville Green Development site will be at a reduced level and comparatively speaking, for CJMR, a reduction of as much as 50% with reference to the Halton Hospital calculations done in 2009.

• The licensed service territory for the two radio stations and their respective antenna patterns are considered to be similar to those identified in the original Lehman and Associates, M.A. Tilston Engineering Report13 reviewed back in 2009. To be more accurate, a copy of the radio stations current antenna radiation pattern should be requested or the most recent Proof of Performance submissions to ISED which appear to have been submitted in 20161.

• Calculation estimates back in 2009 were based on a worst-case scenario where the full transmitter power was directed at the Halton Hospital Site. This approach which proved to meet and exceed all Safety Code 6 limits is overly conservative as the “Back Lobe” and “Minor Side Lobes” of the antenna pattern design characteristics will never be at the same power levels as the main lobe. The Tower site and antenna array physical design and placement are always optimized to maximize transmitter power in the direction of the licensed serving areas and nulls and side lobes designed to restrict the energy from travelling in all directions. This is intentional to minimize potential interference with other AM stations in the region.

• During construction, the height of the cranes which will be needed to construct the four (4) fifteen (15) story buildings will align more closely with the antenna tower heights. As the crane height approaches the one-quarter (¼) wavelength tuned frequency of the antennas (~60 m), there will be a more efficient induced coupling of the radio station RF energy onto the metallic crane boom, thus causing reradiation of the signal back to the tower site antennas, potentially impacting the radio stations, through distortion of their licensed antenna pattern. There is also a risk of increased touch potential or contact currents by the workers in and around the crane, the crane operators and any metallic hoist lines, light poles and other sizable metallic objects.

• The updated 2015 Safety Code 6 guidelines will be used to reference the limits of RF radiation levels allowed for the safety of the workers during construction and the occupants and visitors of the buildings after construction.

5.1 TECHNICAL DISCUSSION AND CONSIDERATIONS

There are a number of technical considerations that need to be factored into this review. Specifically;

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1) Free Space Path Loss and Attenuation of Electromagnetic Radio Waves 2) Distances from the tower site to the boundary of the proposed development 3) Directive antenna characteristics 5.1.1 Free Space Path Loss, Attenuation of Electromagnetic Radio Waves

When radio signals travel through the air from a transmit source antenna to a receive antenna, they will suffer a loss of strength due to signal spreading. The farther the distance between the transmit and receive antenna, the wider the "spread" of the signal and the greater the free space path loss (FSPL).

Free-space path loss (FSPL) is the loss in signal strength of an electromagnetic wave that would result from a line-of-sight path through free space, with no obstacles nearby. When there are obstacles or structures in the path, including terrain anomalies, the free space path loss is impacted by reflection and diffraction of the signal which can further attenuate and distort the traveling electromagnetic wave that is received by the intended receiver.

In our case, there are terrain impacts at or near the ground elevation, but as we increase in height, the free space calculation estimates will more closely predict measured values. These estimates will represent the conservative worst case for us as they don’t consider other variables which impact path loss, such as refraction, diffraction, reflection, coupling losses or absorption. Any of these other considerations will further increase the Path Loss between the source antenna and the receive antenna which will reduce the expected Signal field strength.

The rate at which the level of the signal falls is inversely proportional to the square of the distance it has traveled and is also frequency dependent. Higher frequency electromagnetic waves attenuate more quickly over distance. The formula for Path Loss which was used in our estimates contains the following components:

Free Space Loss (FSPL) :

FSPL (dB) = 20 x LOG10 (Frequency (Mhz) + 20 x LOG10 (Distance (Km)) + 32.44

In our case, the distance to the Eastern Edge of the development is estimated at ~490m while the outer edge at Third Line is estimated at ~870m. The development plot shown the majority of the development concentrated closer to the 870m edge (between ~600m and ~850m) with no development proposed near the 490m property edge. The estimated Free Space Path Loss for both CJMR and CJYE at their respective operating frequencies are shown in the Table below:

Free Space Path Loss Estimates (dB) Distance CJMR @ 1320 Khz CJYE @1250 Khz 490 m -28.7 -28.2 870 m -33.6 -33.2

Table 6 Free Space Path Loss Estimates

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Figure 1 Free Space Path Loss Estimates

Figure 2 Distance circle to Eastern edge of proposed development site

Figure 3 Distance circle to Western edge (Third Line) of the proposed development site

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Figure 4 Proposed Plot Plan and site development

Figure 5 Glenn Abbey Subdivision and other Buildings in close proximity of tower site

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5.1.2 Typical Directive Antenna Pattern Characteristics

The following figure describes the typical directive antenna pattern used throughout the Broadcast Industry. The antenna pattern for both CJMR and CJYE can be characterized by this representation. The modelled radiation patterns for the two radio stations, from the LBA report4 are also presented here.

Figure 6 Typical 2D Directive Antenna Power Pattern13 and CJMR/CJYE patterns1

The above figure suggests that the “Back Lobe” at ~180 degrees from the main lobe direction presents the greatest attenuation from the main lobe power. Typically, the Back Lobe is between 15 dB and 20 dB lower in power levels from the main lobe. This makes perfect sense since the objective is to point the maximum signal power lobe towards the licensed servicing area of the radio station. The back-lobe signal beam also reaches customers but at a much-reduced distance. It is also designed this way to minimize or prevent interference to other AM radio stations in the region.

This is clear from the CJMR and CJYE antenna patterns presented above in Figure 61. According to the LBA report3, these polar plots indicate that the Minor Lobes including the Back Lobe are 15 dB to 20 dB below the Main Lobe reference at 0.0 dB.

The M.A. Tilston Engineering report1 includes actual measured “Back Lobe” zone signal strength at 1km distance are approximately 5-10 times smaller than in the main lobe (400 mV/m versus 2500 mV/m).

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Initial Conditions May 8, 2019

Also note that the licensed transmitter power levels for CJMR was at 20 kW in 1992 and in 2009 whereas now the power levels of both stations have been normalized to 10 kW since they are configured in a Time Multiplexed (TDM) signal transmission format.

Figure 7 Proof of Performance for CJMR and CJYE (Formerly CHWO) Radiation Patterns (1992)1

5.1.3 Internal Electrical Field Strength

This measure is not relevant to us as the proposed development is in the far-field zone. The internal Electric Field Strength limit in the Safety Code 6 Table 2 suggests that Field Strength levels approaching 169 V/m (1.35X10-4X1.25X106 = 168.8 V/m) would be required to violate the limit. This could only occur within very close proximity of the physical transmitters inside the radio station antenna array property boundary. We can confidently conclude that Internal Electrical Field Strength limits as set out in Safety Code 6 will not be violated.

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5.1.4 Signal Strength Calculations

To develop accurate calculations for received Signal Strength at the proposed site requires that the following key parameters be known; specifically;

• Actual Effective Radiated Power (E.R.P), 10kW assumed • Actual antenna Losses, dielectric losses, conduction losses, polarization losses and radiation efficiency • Antenna array mismatch losses, transmission line losses, connector losses, • Licensed antenna pattern as submitted to ISED, through current Proof of Performance • Terrain conditions, obstacles, water, valleys, trees, ground conductivity, Power lines, etc • Final building geometry of the proposed development, understructure, internal and external materials used in the construction of the site structures and completed heights of the structures

These localized anomalies and unknowns are impractical to include and consider in this review. We have chosen to simplify the calculation estimates by considering free space attenuation of radio waves which are distance and frequency dependent, leveraging the property that field strength varies inversely with distance from the source antenna. These estimates can be relied upon to provide a reasonable approximation of the Field Strength which will be present at the proposed development site given ideal conditions.

Given the North arrow position in the Proof of Performance Radiation Patterns in Figure 7 above, we can conclude that the “Back Lobe” power levels which were measured at 1 km from the tower site are a valid approximation of expected power levels at the proposed Oakville Green development site. For completeness, we have also calculated the theoretical levels based on a worst-case scenario for each radio station using transmitter power levels at the full 10 kW.

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Initial Conditions May 8, 2019

CJYE AM - 10KW - 1250 Khz (1.25 Mhz) CJMR AM - 10KW - 1320 Khz (1.32 Mhz) Main Lobe Back Lobe Back Lobe Main Lobe Back Lobe Back Lobe (0 dB) (-15 dB) (-18 dB) (0 dB) (-15 dB) (-18 dB) Effective Tx Power (W): 10,000 300 150 Effective Tx Power (W): 10,000 300 150 Tx dBm: 70.0 54.8 51.8 Tx dBm: 70.0 54.8 51.8 FSPL (dB): -33.2 -33.2 -33.2 FSPL (dB): -33.6 -33.6 -33.6 Rx dBm: 36.8 21.6 18.6 Rx dBm: 36.4 21.1 18.1 Rx dBuV: 144 129 126 Rx dBuV: 143 128 125 Rx dBuV/m: 115.0 99.7 96.7 Rx dBuV/m: 114.5 99.3 96.3 Rx uV/m: 560,378 97,060 68,632 Rx uV/m: 530,661 91,913 64,992 Rx mV/m: 560.4 97.1 68.6 Rx mV/m: 530.7 91.9 65.0 Rx V/m (RMS): 0.396 0.069 0.049 Rx V/m (RMS): 0.375 0.065 0.046

Speed of Light (c): 3.00E+08 m/s Speed of Light (c): 3.00E+08 m/s Distance (km): 870 m Distance (km): 870 m Frequency (Hz): 1.25E+06 Hz Frequency (Hz): 1.32E+06 Hz Free Space Loss (FSPL): -33.17 dB Free Space Loss (FSPL): -33.64 dB

CJYE AM - 10KW - 1250 Khz (1.25 Mhz) CJMR AM - 10KW - 1320 Khz (1.32 Mhz) Main Lobe Back Lobe Back Lobe Main Lobe Back Lobe Back Lobe (0 dB) (-15 dB) (-18 dB) (0 dB) (-15 dB) (-18 dB) Effective Tx Power (W): 10,000 300 150 Effective Tx Power (W): 10,000 300 150 Tx dBm: 70.0 54.8 51.8 Tx dBm: 70.0 54.8 51.8 FSPL (dB): -28.2 -28.2 -28.2 FSPL (dB): -28.7 -28.7 -28.7 Rx dBm: 41.8 26.6 23.6 Rx dBm: 41.3 26.1 23.1 Rx dBuV: 149 134 131 Rx dBuV: 148 133 130 Rx dBuV/m: 120.0 104.7 101.7 Rx dBuV/m: 119.5 104.3 101.2 Rx uV/m: 994,956 172,331 121,857 Rx uV/m: 942,193 163,193 115,395 Rx mV/m: 995.0 172.3 121.9 Rx mV/m: 942.2 163.2 115.4 Rx V/m (RMS): 0.704 0.122 0.086 Rx V/m (RMS): 0.666 0.115 0.082

Speed of Light (c): 3.00E+08 m/s Speed of Light (c): 3.00E+08 m/s Distance (km): 490 m Distance (km): 490 m Frequency (Hz): 1.25E+06 Hz Frequency (Hz): 1.32E+06 Hz Free Space Loss (FSPL): -28.18 dB Free Space Loss (FSPL): -28.66 dB

Figure 8 Estimated Signal Strength (dBuV/m and V/m) for CJMR and CJYE signals at the Oakville Green Development Site using Free Space Loss Estimates

The two radio stations both operating at 10 kW and co-sited at the same tower location could potentially 2 cause a combined effect of an additional +41% impact to their Effective Radiated Power since E0={E1 + 2 0.5 E2 } RMS, thus elevating the received field strength at the proposed site. Given that the stations are now sharing the site on a Time Multiplex basis (TDM), we can conclude that the two stations are never transmitting their effective radiated power levels at the same time. By definition, TDM (Time Division Multiplex) is based on signal transmission occurring in separated time slots to prevent intermodulation interference, reradiation and potential mixing distortions in the desired radiated signal. The transmission of the two (2) signals has been separated in both frequency and in time. We have provided a view of the potential impact that this worst-case component would have on the received Electrical Field strength if the stations are co-sited without TDM. This scenario still produces worst-case field strength values which are well within the Safety Code 6 limits for human safety.

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Initial Conditions May 8, 2019

CJYE/CJMR AM - 10KW - CO-SITED Main Lobe Back Lobe Back Lobe (0 dB) (-15 dB) (-18 dB) Effective Combined Tx Power (W): 14,100 423 212 Tx dBm: 71.5 56.3 53.3 FSPL (dB): -33.2 -33.2 -33.2 Rx dBm: 38.3 23.1 20.1 Rx dBuV: 145 130 127 Rx dBuV/m: 116.5 101.2 98.2 Rx uV/m: 665,412 115,253 81,496 Rx mV/m: 665.4 115.3 81.5 Rx V/m (RMS): 0.471 0.081 0.058

Speed of Light (c): 3.00E+08 m/s Distance (km): 870 m Frequency (Hz): 1.25E+06 Hz Free Space Loss (FSPL): -33.17 dB

CJYE AM - 10KW - 1250 Khz (1.25 Mhz) Main Lobe Back Lobe Back Lobe (0 dB) (-15 dB) (-18 dB) Effective Tx Power (W): 14,100 423 212 Tx dBm: 71.5 56.3 53.3 FSPL (dB): -28.2 -28.2 -28.2 Rx dBm: 43.3 28.1 25.1 Rx W: 21.4 0.6 0.3 Rx dBuV: 150 135 132 Rx dBuV/m: 121.4 106.2 103.2 Rx uV/m: 1,181,445 204,632 144,697 Rx mV/m: 1,181.4 204.6 144.7 Rx V/m (RMS): 0.835 0.145 0.102

Speed of Light (c): 3.00E+08 m/s Distance (km): 490 m Frequency (Hz): 1.25E+06 Hz Free Space Loss (FSPL): -28.18 dB

Figure 9 Estimated Signal Strength (dBuV/m and V/m) for CJMR and CJYE signals at the Oakville Green Development Site considering combined effect of co-sited non TDM operation.

0.5 The Safety Code 6 limits for Electrical Field Strength in an uncontrolled environment is 87/f V/m RMS which for CJMR operating at 1.32 Mhz, translates to 75.7 V/m RMS. Our calculation estimates the worst- case Electrical Field strength is at 0.666 V/m RMS. This level falls just below 1% of the Safety Code 6 Electrical Field Strength limit.

For CJYE operating at 1.25 Mhz, our calculation estimates the worst-case Electrical Field Strength at 0.704 V/m RMS which also falls just below 1% of the Safety Code 6 Electrical Field strength limit.

The combined effect of the two stations operating simultaneously and co-sited would increase the levels to a worst-case figure of 0.835 V/m RMS which is still well below the Safety Code 6 limits. We can confidently conclude that Electrical Field Strength levels at the site will not violate the limits of Safety Code 6.

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5.1.5 Induced and Contact Currents

Contact current can exceed the current limits specified in Safety Code 6, even though the Electric Field Strengths, which are the major contributor to the contact current, are below the limits. However, this reference by ISED in their TN-329 Technical Note; “Safety Code 6 (SC6) Measurement Procedures (Uncontrolled Environment)”5 suggests that these conditions “may occur” when the Electric Field Strength is as low as 25% of the exposure limit. In our case, the Electrical Field Strength is substantially below the 25% figure and therefore, it is reasonable to conclude that the Induced currents associated with these low levels of Electrical Field strength will not be of concern to Human Safety.

The height of the proposed buildings on the site is such that they are very close to the ¼ wavelength of the two frequencies. Specifically, close to 56.8m and 60m for CJMR and CJYE respectively. This suggests that the signal coupling or induced current levels on those buildings will be optimized and could cause “startle effect” issues during construction at the site.

To mitigate these concerns, once site detailed design is completed, technical modelling of the buildings impact to the radio station licensed radiation pattern should be completed. Significant distortion of the radiation pattern, especially in the Back Lobe and Minor Lobes could add substantially to the received Electrical field strength at the proposed site and elevate contact currents.

Although, we can confidently conclude that contact current levels will not violate the Safety Code 6 limits at the site distance, it is recommended that mitigation strategies be considered during the construction phase since even with these lower levels of contact currents, there is always a possibility of “startle affect” impact.

5.1.6 Magnetic Field Strength

The Magnetic Field Strengths of various AM Radio station Transmitters and their predicted safe distances from the base of the towers are shown in Table 7 below, extracted from FCC OET Bulletin 654. It is readily seen that exposure contours for a 10 kW transmitter fall off below 25 V/m within a distance of only 60 meters from the tower base. The Safety Code 6 limits for both Electrical and Magnetic Field Strength 0.5 are 87/f V/m RMS ( 75.7 V/m RMS ) and 0.73/f A/m RMS ( 0.41 A/m RMS ) respectively. Since the proposed development is ~850 m from the tower site, we can confidently conclude that the Magnetic field strength at the site will not violate the limits of Safety Code 6.

This Table according to the ISED TN-3295 is valid and can be used for all AM frequencies and tower heights. The entries in this table apply to both Electric Field Strength and the corresponding Magnetic Field Strength (assuming a free-space intrinsic impedance equal to 377 Ohms).

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Table 7 Location Prediction of Exposure Contours for AM Antenna Systems

5.1.7 Re-Radiation Concerns

It is important to establish some basic framework and understanding around the parameters which govern the issues and concerns being raised by the radio station consultants. It is important to acknowledge that RF signal energy is found everywhere on this planet and re-radiation occurs commonly with all types of signal transmission regardless of frequency, type of service, source devices, temperatures and building heights. If there are metallic objects or structures which are in the path of RF signals, there will be re- radiation when the RF signal energy comes into contact with the structures. The amount and efficiency of the induced coupling is proportional to the frequency in question, the transmitter power levels and the design and configuration of the signal source antennae. The end result impact to the source antenna radiation pattern is also governed by the re-radiating object wavelength distance from the source antennae which controls the arriving phase of the re-radiated signal. If it arrives back at the source

OAKVILLE GREEN DEVELOPMENT – AM RADIO RF ENERGY ASSESSMENT

Initial Conditions May 8, 2019 antenna in phase, it will add to the effective transmitter power level and if it arrives out of phase it will potentially distort and reduce the effective transmitter power level.

This phenomenon is correctly described in the original Lehman and Associates, M.A. Tilston report 13, and can cause intended signal distortion through signal delays from the re-radiation and as described above, depending on the phases of the reradiated waves when they arrive back at the transmitting antenna. The resulting signal can be distorted in both amplitude and content quality from frequencies mixing with each other. Also, since there are hundreds of AM radio stations throughout North America, with a myriad of antenna pattern designs, coordination efforts must also be made to minimize the interference (ie. unwanted signals of the same frequency) to other licensed stations within reach of the station’s transmitter power. This distortion ultimately causes degradation to the reception of the signal by the intended end subscribers to the radio service, and this is why radio station antenna pattern design, frequency assignment and transmitter power are carefully engineered and coordinated by government agencies to try to minimize the impact of re-radiation.

5.1.8 Building Heights

As stated, reradiation is directly proportional to the incident field strength received by the structure. As the distance from the transmitter site increases, the field strength decreases and so does the level of reradiation. Also, as the building height decreases below the one-quarter (¼) wavelength of the antenna tuned frequency, the level of reradiation also decreases. Further, as the building height increases beyond one-quarter (¼) wavelength, the reradiation curve tends to flatten out without further increases in reradiation levels.

The height of the proposed buildings at the Oakville Green Development site will range from 57.5 meters to 63.5 meters. At this point we don’t know the final building geometry, the interior understructure or the outside building materials which will be used. Without this information, modelling the impact of the re- radiation to the radio station licensed antenna radiation pattern cannot be done with a high level of confidence. Re-radiation cannot be mitigated easily and therefore should be modelled once final design of the buildings is completed. Greater depth of discussion on this subject is beyond the scope of this initial review and assessment. The proposed preliminary building heights and elevations can be found in Appendix C.

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References May 8, 2019

6.0 REFERENCES

1) Compressed_O'Connor MacLeod Hanna Comments_Redacted, dated March 14, 2019 2) Martillac, Graydon-Banning and Oakville Green Life Sciences and Technology District, extracted from Compressed_O'Connor MacLeod Hanna Comments_Redacted 3) Safety Code 6 (2015); Limits of Human Exposure to Radiofrequency Electromagnetic Energy in the Frequency Range From 3 Khz TO 300 Ghz 4) Lawrence Behr Associates extract from Compressed_O'Connor MacLeod Hanna Comments_Redacted 5) TN-329 Technical Note; Safety Code 6 (SC6) Measurement Procedures (Uncontrolled Environment) 6) TN-261, Issue 3, Safety Code 6 (SC6) Radio Frequency Exposure Evaluation Template (Uncontrolled Environment Exposure Limits), replaces TN-261, Issue 2, published in December 2012. 7) Federal Communications Commission (FCC) OET65 (http://www.fcc.gov/oet/info/documents/bulletins/) 8) Broadcasting Procedures and Spectrum Management and Telecommunications, Part 2 - BPR-2 Issue 3, February 2016 9) Letter from EllesDon Dated April 18, 2019 10) ISED publication entitles; CPC-2-0-03 — Radiocommunication and Broadcasting Antenna Systems 11) ISED publication entitled; Canadian Municipalities and the Regulation of Radio Antennae and their Support Structures 12) GL01-Issue 3; Guidelines for the Measurement of Radio Frequency Fields at Frequencies From 3 kHz to 300 GHz 13) Fundamental Antenna Parameters: by Prof. Natalia K. Nikolova, McMaster University 14) Lehman and Associates, M.A. Tilston Engineering, February 1993 15) CPC-2-0-03 — Radiocommunication and Broadcasting Antenna Systems, ISED Publication, Effective: July 15, 2014

OAKVILLE GREEN DEVELOPMENT – AM RADIO RF ENERGY ASSESSMENT

Appendix A May 8, 2019

APPENDIX A Safety Code 6, 2015

OAKVILLE GREEN DEVELOPMENT – AM RADIO RF ENERGY ASSESSMENT

Appendix A May 8, 2019

Appendix A

A.1 SAFETY CODE 6, 2015

LIMITS OF HUMAN EXPOSURE TO RADIOFREQUENCY ELECTROMAGNETIC ENERGY IN THE FREQUENCY RANGE FROM 3 KHZ TO 300 GHZ

Consumer and Clinical Radiation Protection Bureau Environmental and Radiation Health Sciences Directorate Healthy Environments and Consumer Safety Branch Health Canada

SAFETY CODE 6 (2015) Health Canada is the federal department responsible for helping the people of Canada maintain and improve their health. We assess the safety of drugs and many consumer products, help improve the safety of food, and provide information to Canadians to help them make healthy decisions. We provide health services to First Nations people and to Inuit communities. We work with the provinces to ensure our health care system serves the needs of Canadians.

Également disponible en français sous le titre : Limites d’exposition humaine à l’énergie électromagnétique radioélectrique dans la gamme de fréquences de 3 kHz à 300 GHz

To obtain additional information, please contact: Health Canada Address Locator 0900C2 Ottawa, ON K1A 0K9 Tel.: 613-957-2991 Toll free: 1-866-225-0709 Fax: 613-941-5366 TTY: 1-800-465-7735 E-mail: [email protected]

This publication can be made available in alternative formats upon request.

Publication date: June 2015

This publication may be reproduced for personal or internal use only without permission provided the source is fully acknowledged.

Cat.: H129-48/2015E-PDF ISBN: 978-0-660-02466-0 Pub.: 150021 PREFACE This document is one of a series of safety codes prepared by the Consumer and Clinical Radiation Protection Bureau, Health Canada. These safety codes specify the requirements for the safe use of, or exposure to, radiation emitting devices. This revision replaces the previous version of Safety Code 6 (2009). The purpose of this code is to establish safety limits for human exposure to radiofrequency (RF) fields in the frequency range from 3 kHz to 300 GHz. The safety limits in this code apply to all individuals working at, or visiting, federally regulated sites. These guidelines may also be adopted by the provinces, industry or other interested parties. The Department of National Defence shall conform to the requirements of this safety code, except in such cases where it considers such compliance to have a detrimental effect on its activities in support of training and operations of the Canadian Forces. This code has been adopted as the scientific basis for equipment certification and RF field exposure compliance specifications outlined in Industry Canada’s regulatory documents (1–3), that govern the use of wireless devices in Canada, such as cell phones, cell towers (base stations) and broadcast antennas. Safety Code 6 does not apply to the deliberate exposure for treatment of patients by, or under the direction of, medical practitioners. Safety Code 6 is not intended for use as a product performance specification document, as the limits in this safety code are for controlling human exposure and are independent of the source of RF energy. In a field where technology is advancing rapidly and where unexpected and unique exposure scenarios may occur, this code cannot cover all possible situations. Consequently, the specifications in this code may require interpretation under special circumstances. This interpretation should be done in consultation with scientific staff at the Consumer and Clinical Radiation Protection Bureau, Health Canada. The safety limits in this code are based on an ongoing review of published scientific studies on the health impacts of RF energy and how it interacts with the human body. This code is periodically revised to reflect new knowledge in the scientific literature and the exposure limits may be modified, if deemed necessary.

LIMITS OF HUMAN EXPOSURE TO RADIOFREQUENCY ELECTROMAGNETIC ENERGY IN THE FREQUENCY RANGE FROM 3 KHZ TO 300 GHZ > I II > LIMITS OF HUMAN EXPOSURE TO RADIOFREQUENCY ELECTROMAGNETIC ENERGY IN THE FREQUENCY RANGE FROM 3 KHZ TO 300 GHZ TABLE OF CONTENTS

PREFACE...... I

1. INTRODUCTION...... 1 1.1 Purpose of the code...... 2

2. MAXIMUM EXPOSURE LIMITS...... 2 2.1 Basic Restrictions...... 4 2.1.1 Internal Electric Field Strength Limits (3 kHz–10 MHz)...... 4 2.1.2 Specific Absorption Rate Limits (100 kHz–6 GHz)...... 5 2.1.3 Frequencies from 6 GHz–300 GHz...... 5

2.2 Reference Levels...... 6 2.2.1 Electric and Magnetic Field Strength (3 kHz–10 MHz)...... 6 2.2.2 Electric Field Strength, Magnetic Field Strength and Power Density (10 MHz–300 GHz)...... 8 2.2.3 Induced and Contact Current (3 kHz–110 MHz)...... 10

ABBREVIATIONS...... 12 DEFINITIONS...... 13 REFERENCES...... 15

LIMITS OF HUMAN EXPOSURE TO RADIOFREQUENCY ELECTROMAGNETIC ENERGY IN THE FREQUENCY RANGE FROM 3 KHZ TO 300 GHZ > III IV > LIMITS OF HUMAN EXPOSURE TO RADIOFREQUENCY ELECTROMAGNETIC ENERGY IN THE FREQUENCY RANGE FROM 3 KHZ TO 300 GHZ 1. INTRODUCTION Electromagnetic radiation is emitted by many natural and man-made sources and is a fundamental aspect of our lives. We are warmed by electromagnetic radiation emitted from the sun and our eyes can detect the visible light portion of the electromagnetic spectrum. Radiofrequency (RF) fields fall within a portion of the electromagnetic spectrum with frequencies ranging from 3 kHz to 300 GHz, below that of visible light and above that of extremely low frequency electromagnetic fields. RF fields are produced by many man-made sources including cellular (mobile) phones and base stations, television and radio broadcasting facilities, radar, medical equipment, microwave ovens, RF induction heaters as well as a diverse assortment of other electronic devices within our living and working environments. A number of biological effects and established adverse health effects from acute exposure to RF fields have been documented (4–9). These effects relate to localized heating or stimulation of excitable tissue. The specific biological responses to RF fields are generally related to the rate of energy absorbed or the strength of internal electric fields (voltage gradients) and currents. The rate and distribution of RF energy absorption depend strongly on the frequency, strength and orientation of the incident fields as well as the body size and its constitutive electrical properties (dielectric constant and conductivity). Absorption of RF energy is commonly described in terms of the specific absorption rate (SAR), which is a measure of the rate of energy deposition per unit mass of body tissue and is usually expressed in units of watts per kilogram (W/kg). Based on a large amount of scientific knowledge, national and international exposure limits have been established to protect the general public against all adverse effects associated with RF field exposures (10–14). The exposure limits specified in Safety Code 6 have been established based upon a thorough evaluation of the scientific literature related to the thermal and non-thermal health effects of RF fields. Health Canada scientists consider all peer-reviewed scientific studies, on an ongoing basis, and employ a weight-of-evidence approach when evaluating the possible health risks of exposure to RF fields. This approach takes into account the quantity of studies on a particular endpoint (whether adverse or no effect), but more importantly, the quality of those studies. Poorly conducted studies (e.g. those with incomplete dosimetry or inadequate control samples) receive relatively little weight, while properly conducted studies (e.g. all controls included, appropriate statistics, complete dosimetry) receive more weight. The exposure limits in Safety Code 6 are based upon the lowest exposure level at which any scientifically established adverse health effect occurs. Safety margins have been incorporated into the exposure limits to ensure that even worst-case exposures remain far below the threshold for harm. The scientific approach used to establish the exposure limits in Safety Code 6 is comparable to that employed by other science-based international standards bodies (15–16). As such, the basic restrictions in Safety Code 6 are similar to those adopted by most other nations, since all science-based, standard- setting bodies use the same scientific data. It must be stressed that Safety Code 6 is based upon established adverse health effects and should be distinguished from some municipal and/or national guidelines that are based on socio-political considerations. In the following sections, the maximum exposure levels for persons in both controlled and uncontrolled environments are specified. These levels shall not be exceeded.

LIMITS OF HUMAN EXPOSURE TO RADIOFREQUENCY ELECTROMAGNETIC ENERGY IN THE FREQUENCY RANGE FROM 3 KHZ TO 300 GHZ > 1 1.1 PURPOSE OF THE CODE The purpose of this code is to specify maximum levels of human exposure to RF fields at frequencies between 3 kHz and 300 GHz, to prevent adverse human health effects in both controlled and uncontrolled environments. In this code, controlled environments are defined as those where all of the following conditions are satisfied: (a) the RF field intensities in the controlled area have been adequately characterized by means of measurements or calculation, (b) the exposure is incurred by persons who are aware of the potential for RF exposure and are cognizant of the intensity of the RF fields in their environment and, (c) the exposure is incurred by persons who are aware of the potential health risks associated with RF field exposures and can control their risk using mitigation strategies.

Situations that do not meet all the specifications above are considered to be uncontrolled environments. Uncontrolled environments are defined as areas where either insufficient assessment of RF fields has been conducted or where persons who are allowed access to these areas have not received proper RF field awareness/safety training and have no means to assess or, if required, to mitigate their exposure to RF fields. 2. MAXIMUM EXPOSURE LIMITS The scientific literature with respect to possible biological effects of RF fields has been monitored by Health Canada scientists on an ongoing basis. Since the last version of Safety Code 6 was published (2009), a significant number of new studies have evaluated the potential for acute and chronic RF field exposures to elicit possible effects on a wide range of biological endpoints including: human cancers; rodent lifetime mortality; tumor initiation, promotion and co-promotion; mutagenicity and DNA damage; EEG activity; memory, behaviour and cognitive functions; gene and protein expression; cardiovascular function; immune response; reproductive outcomes; and perceived electromagnetic hypersensitivity among others. Numerous authoritative reviews have summarized the current literature (4–8, 17–40). Despite the advent of numerous additional research studies on RF fields and health, the only established adverse health effects associated with RF field exposures in the frequency range from 3 kHz to 300 GHz relate to the occurrence of tissue heating and nerve stimulation (NS) from short-term (acute) exposures. At present, there is no scientific basis for the occurrence of acute, chronic and/or cumulative adverse health risks from RF field exposure at levels below the limits outlined in Safety Code 6. The hypotheses of other proposed adverse health effects occurring at levels below the exposure limits outlined in Safety Code 6 suffer from a lack of evidence of causality, biological plausibility and reproducibility and do not provide a credible foundation for making science-based recommendations for limiting human exposures to low-intensity RF fields. This safety code provides guidance for the avoidance of adverse human health effects resulting from exposure to RF fields, in terms of basic restrictions and/or reference levels. Basic restrictions are exposure indices within the body that should not be exceeded. These exposure indices are

2 > LIMITS OF HUMAN EXPOSURE TO RADIOFREQUENCY ELECTROMAGNETIC ENERGY IN THE FREQUENCY RANGE FROM 3 KHZ TO 300 GHZ directly linked to established adverse health effects. The basic restrictions in this safety code are specified in terms of: a) internal electric field strength; and b) the rate of RF energy absorption (SAR). Since measurements of the SAR or internal electric field strength are often difficult to perform, reference levels for maximum human exposure to RF fields have also been specified in this safety code. The reference levels are specified in terms of unperturbed, externally applied electric- and magnetic-field strength, power density and in terms of electric currents in the body occurring from either induction or contact with energized metallic objects. They were established using dosimetric analyses that determined the levels of externally applied field strengths that would produce the basic restrictions within the body. While compliance with the basic restrictions is required, non-compliance with the reference levels does not necessarily mean that the basic restrictions are not respected. In such cases, additional measurements or calculations may be required to assess compliance. For frequencies from 3 kHz to 10 MHz, NS from induced electric fields within the body must be avoided. Experimental studies have demonstrated that electric and magnetic field exposures can induce internal electric fields (voltage gradients) within biological tissue which, if sufficiently intense, can alter the “resting” membrane potential of excitable tissues resulting in spontaneous depolarization of the membrane and the generation of spurious action potentials (5, 10, 11, 13, 14, 35, 41). Basic restrictions for the avoidance of NS are specified in this safety code in terms of maximum internal electric field strength within the body. For frequencies from 100 kHz to 300 GHz, tissue heating can occur and must be limited. Basic restrictions have been specified in this safety code for RF field exposures in the 100 kHz to 6 GHz frequency range, in terms of maximum whole-body SAR (averaged over the whole-body) and peak spatially-averaged SAR, (averaged over a small cubical volume). For frequencies above 6 GHz, RF energy absorption occurs predominantly in surface tissues (e.g. upper layers of skin) and the use of maximum SAR limits, either whole-body or averaged over a cubical volume, is not appropriate. In lieu of basic restrictions, reference levels are specified for maximum unperturbed, externally applied electric- and magnetic-field strengths and in terms of power density, for the avoidance of thermal effects. Studies in animals, including non-human primates, have consistently demonstrated a threshold effect for the occurrence of behavioural changes and alterations in core body temperature of o ~1.0 C, at a whole-body average SAR of ~4 W/kg (5–8, 11, 12, 14, 36). Thermoregulatory studies in human volunteers exposed to RF fields under a variety of exposure scenarios have provided supporting information on RF field induced thermal responses in humans (42). This information forms the scientific basis for the basic restrictions on whole-body average SAR in Safety Code 6. To ensure that thermal effects are avoided, safety factors have been incorporated into the exposure limits, resulting in whole-body-averaged SAR limits of 0.08 and 0.4 W/kg in uncontrolled- and controlled-environments, respectively. Basic restrictions on peak spatially-averaged SAR have also been established in Safety Code 6 to avoid adverse thermal effects in localized human tissues (hot-spots). The peak spatially-averaged SAR limits reflect the highly heterogeneous nature of typical RF field exposures and the differing thermoregulatory properties of various body tissues. The peak spatially-averaged SAR limits pertain to discrete tissue volumes (1 or 10 g, in the shape of a cube), where thermoregulation can efficiently dissipate heat and avoid changes in body temperature that are greater than 1oC.

LIMITS OF HUMAN EXPOSURE TO RADIOFREQUENCY ELECTROMAGNETIC ENERGY IN THE FREQUENCY RANGE FROM 3 KHZ TO 300 GHZ > 3 As such, the peak spatially-averaged SAR limits for exposures in controlled environments are 20 W/kg for the limbs and 8 W/kg for the head, neck and trunk. For exposures in uncontrolled environments, the peak spatially-averaged SAR limits are 4.0 W/kg for the limbs and 1.6 W/kg for the head, neck and trunk. For frequencies from 100 kHz to 10 MHz, since either NS or thermal effects could occur, depending upon the exposure conditions (frequency, duty cycle, orientation), basic restrictions for both internal electric field strength and SAR (whole-body and peak spatially-averaged) must be simultaneously respected. Safety Code 6 also specifies reference levels in the 3 kHz to 110 MHz frequency range, in terms of induced- or contact-currents (mA), for the avoidance of perception (nerve stimulation), shocks or burns (4, 6). While the biological basis for the basic restrictions specified in this safety code has not changed since the previous version (2009), the reference levels have been updated to either account for dosimetric refinements in recent years (43–64) or where feasible, to harmonize with those of ICNIRP (10–11). To determine whether the maximum exposure levels are exceeded, full consideration shall be given to such factors as: (a) nature of the exposure environment (controlled or uncontrolled environment); (b) temporal characteristics of the RF source (including ON/OFF times, duty factors, direction and sweep time of the beam, etc.); (c) spatial characteristics between the exposure source and target (i.e. near-field exposures, whole body or parts thereof); (d) uniformity of the exposure field (i.e. spatial averaging).

Where comparison is to be made to the SAR-based basic restrictions and/or reference levels at frequencies in the 100 kHz–300 GHz range, higher exposure levels may be permitted for short durations of time under certain circumstances. For these situations, the field strengths, power densities and body currents averaged over any one tenth-hour reference period (6 minutes) shall not exceed the limits outlined in Sections 2.1 and 2.2. SI units are used throughout this document unless specified otherwise.

2.1 BASIC RESTRICTIONS 2.1.1 Internal Electric Field Strength Limits (3 kHz–10 MHz) Limits for internal electric field strength are intended to prevent the occurrence of NS. At frequencies between 3 kHz and 10 MHz, basic restrictions for internal electric field strength in excitable tissues (Table 1) shall not be exceeded. For conditions where the determination of internal electric field strength is not possible or practical (e.g. by measurement or modelling), external unperturbed field strength assessment shall be carried out and the reference levels outlined in Section 2.2 shall be respected.

4 > LIMITS OF HUMAN EXPOSURE TO RADIOFREQUENCY ELECTROMAGNETIC ENERGY IN THE FREQUENCY RANGE FROM 3 KHZ TO 300 GHZ TABLE 1: Internal Electric Field Strength Basic Restrictions (3 kHz–10 MHz)

Internal Electric Field Strength CONDITION (V/m) (in any excitable tissue) Controlled Environment 2.7 x 10-4ƒ Uncontrolled Environment 1.35 x 10-4ƒ

Frequency, ƒ, is in Hz. Instantaneous, root mean square (RMS) values apply. In the case of RF fields with amplitude modulation, then RMS values during the maximum of the modulation envelope shall apply.

2.1.2 Specific Absorption Rate Limits (100 kHz–6 GHz) The SAR is a measure of the rate at which electromagnetic energy is absorbed in the body. Basic restrictions for SAR are intended to prevent the occurrence of thermal effects from RF energy exposure on the body. At frequencies between 100 kHz and 6 GHz, the SAR limits (Table 2) take precedence over field strength and power density reference levels (Section 2.2) and shall not be exceeded. The SAR should be determined for situations where exposures occur at a distance of 0.2 m or less from the source. In all cases, the values in Table 2 shall not be exceeded. For conditions where SAR determination is impractical, external unperturbed field strength or power density measurements shall be carried out and the limits outlined in Section 2.2 shall be respected.

TABLE 2: Specific Absorption Rate Basic Restrictions (100 kHz–6 GHz)

SAR Basic Restriction (W/kg)** Uncontrolled Controlled CONDITION Environment Environment The SAR averaged over the whole body mass. 0.08 0.4 The peak spatially-averaged SAR for the head, neck and trunk, averaged over any 1 g of tissue* 1.6 8 The peak spatially-averaged SAR in the limbs, averaged over any 10 g of tissue* 4 20

* Defined as a tissue volume in the shape of a cube. ** Averaged over any 6 minute reference period.

2.1.3 Frequencies from 6 GHz–300 GHz For frequencies above 6 GHz, energy deposition occurs predominantly in the uppermost layers of superficial tissues (e.g. skin, cornea). In this case, power density is a more appropriate exposure limit metric. Therefore, for the frequency range from 6 GHz to 300 GHz, the incident unperturbed power density and its derived electric- and magnetic-field strengths (assuming a free-space impedance of 377 ohms) form the basic restriction in this safety code (Section 2.2.2) and shall not be exceeded.

LIMITS OF HUMAN EXPOSURE TO RADIOFREQUENCY ELECTROMAGNETIC ENERGY IN THE FREQUENCY RANGE FROM 3 KHZ TO 300 GHZ > 5 2.2 REFERENCE LEVELS In practice, direct measurements of internal electric fields or SAR are often only feasible under laboratory conditions. Therefore, reference levels are specified in this safety code in terms of external unperturbed electric and magnetic field strength, power density, as well as induced and contact currents. In the far-field zone of an electromagnetic source, electric field strength, magnetic field strength and power density are interrelated by simple mathematical expressions, where any one of these parameters defines the remaining two. In the near-field zone, both the unperturbed electric- and magnetic-field strengths shall be measured, since there is no simple relationship between these two quantities. Instrumentation for the measurement of magnetic fields at certain frequencies may not be commercially available. In this case, the electric field strength shall be measured and used for assessing compliance with the reference levels in this code.

2.2.1 Electric and Magnetic Field Strength (3 kHz–10 MHz) To ensure compliance with the basic restrictions outlined in Section 2.1, at frequencies between 0.003 MHz and 10 MHz, both the NS- and SAR-based reference levels for electric- and magnetic-field strength must be complied with simultaneously at frequencies where reference levels for both apply.

TABLE 3: Electric Field Strength Reference Levels

Reference Level (ERL), (V/m, RMS) Frequency Reference Uncontrolled Controlled (MHz) Level Basis Environment Environment Reference Period 0.003–10 NS 83 170 Instantaneous* 1.0–10 SAR 87 / ƒ 0.5 193 / ƒ 0.5 6 minutes**

Frequency, ƒ, is in MHz. The precise frequencies at which SAR-based electric field strength reference levels for Uncontrolled and Controlled Environments begin are 1.10 MHz and 1.29 MHz, respectively.

TABLE 4: Magnetic Field Strength Reference Levels

Reference Level (HRL), (A/m, RMS) Frequency Reference Uncontrolled Controlled (MHz) Level Basis Environment Environment Reference Period 0.003–10 NS 90 180 Instantaneous* 0.1–10 SAR 0.73 / ƒ 1.6 / ƒ 6 minutes**

Frequency, ƒ, is in MHz.

NOTES FOR TABLES 3 AND 4: 1. * At no point in time shall the RMS values for electric- and magnetic-fields exceed the reference levels with an instantaneous reference period in Tables 3 and 4. In the case of RF fields with amplitude modulation, the RMS value during the maximum of the modulation envelope shall be compared to the reference level.

6 > LIMITS OF HUMAN EXPOSURE TO RADIOFREQUENCY ELECTROMAGNETIC ENERGY IN THE FREQUENCY RANGE FROM 3 KHZ TO 300 GHZ 2. ** For exposures shorter than the reference period, field strengths may exceed the reference levels, provided that the time average of the squared value of the electric or magnetic field 2 2 strength over any time period equal to the reference period shall not exceed ERL or HRL , respectively. For exposures longer than the reference period, including indefinite exposures, the time average of the squared value of the electric or magnetic field strength over any time 2 2 period equal to the reference period shall not exceed ERL or HRL , respectively. 3. Where external electric (at all applicable frequencies) or magnetic (at frequencies at or above 100 kHz) field strengths are spatially non-uniform, comparison to the reference levels shall be made after spatially averaging the field strengths over the vertical extent of the human body. Where comparison is to be made to the reference levels based on NS in Tables 3 and 4, spatial averaging is with respect to the sample values of the field strengths. Where comparison is to be made to the reference levels based on SAR in Tables 3 and 4, spatial averaging is with respect to the square of the sample values of the field strengths. 4. Where external magnetic field strengths are spatially non-uniform and are below 100 kHz, the spatial peak magnetic field strength over the vertical extent of the human body shall be compared to the reference levels in Table 4 (i.e. magnetic field strengths shall not be spatially-averaged at frequencies below 100 kHz). 5. For simultaneous exposure to multiple frequencies and where comparison is to be made to the reference level based on NS, each of the field strength frequency component amplitudes shall be divided by the corresponding field strength reference level for that frequency, and the sum

of all these ratios shall not exceed unity. This may be expressed as ∑ (Ei/ERL) ≤ 1 for electric field

strength or ∑ (Hi/HRL) ≤ 1 for magnetic field strength. 6. For simultaneous exposure to multiple frequencies and where comparison is to be made to the reference level based on SAR, each of the squares of the field strength frequency component amplitudes shall be divided by the square of the corresponding field strength reference level for that frequency, and the sum of all these ratios shall not exceed unity. This may be expressed 2 2 as ∑ (Ei/ERL) ≤ 1 for electric field strength or ∑ (Hi/HRL) ≤ 1 for magnetic field strength. 7. For localized exposure of the limbs, the reference levels for magnetic field strength may be exceeded provided that the basic restrictions in Table 1 are respected within the limbs.

LIMITS OF HUMAN EXPOSURE TO RADIOFREQUENCY ELECTROMAGNETIC ENERGY IN THE FREQUENCY RANGE FROM 3 KHZ TO 300 GHZ > 7 2.2.2 Electric Field Strength, Magnetic Field Strength and Power Density (10 MHz–300 GHz) To ensure compliance with the basic restrictions outlined in Section 2.1, at frequencies between 10 MHz and 300 GHz, the reference levels for electric- and magnetic-field strength and power density must be complied with.

TABLE 5: Reference Levels for Electric Field Strength, Magnetic Field Strength and Power Density in Uncontrolled Environments

Electric Field Magnetic Field

Frequency Strength (ERL), Strength (HRL), Power Density Reference Period 2 (MHz) (V/m, RMS) (A/m, RMS) (SRL), (W/m ) (minutes) 10–20 27.46 0.0728 2 6 20–48 58.07 / ƒ 0.25 0.1540 / ƒ 0.25 8.944 / ƒ 0.5 6 48–300 22.06 0.05852 1.291 6 300–6000 3.142 ƒ 0.3417 0.008335 ƒ 0.3417 0.02619 ƒ 0.6834 6 6000–15000 61.4 0.163 10 6 15000–150000 61.4 0.163 10 616000 / ƒ 1.2 150000–300000 0.158 ƒ 0.5 4.21x10–4 ƒ 0.5 6.67x10–5 ƒ 616000 / ƒ 1.2

Frequency, ƒ, is in MHz.

TABLE 6: Reference Levels for Electric Field Strength, Magnetic Field Strength and Power Density in Controlled Environments

Electric Field Magnetic Field

Frequency Strength (ERL), Strength (HRL), Power Density, Reference Period 2 (MHz) (V/m, RMS) (A/m, RMS) (SRL), (W/m ) (minutes) 10–20 61.4 0.163 10 6 20–48 129.8 / ƒ 0.25 0.3444 / ƒ 0.25 44.72 / ƒ 0.5 6 48–100 49.33 0.1309 6.455 6 100–6000 15.60 ƒ 0.25 0.04138 ƒ 0.25 0.6455 ƒ 0.5 6 6000–15000 137 0.364 50 6 15000–150000 137 0.364 50 616000 / ƒ 1.2 150000–300000 0.354 ƒ 0.5 9.40x10–4 ƒ 0.5 3.33x10–4 ƒ 616000 / ƒ 1.2

Frequency, ƒ, is in MHz.

NOTES FOR TABLES 5 AND 6: 1. For exposures shorter than the reference period, field strengths may exceed the reference levels, provided that the time average of the squared value of the electric or magnetic field strength 2 2 over any time period equal to the reference period shall not exceed ERL or HRL , respectively. For exposures longer than the reference period, including indefinite exposures, the time average of the squared value of the electric or magnetic field strength over any time period equal to 2 2 the reference period shall not exceed ERL or HRL , respectively.

8 > LIMITS OF HUMAN EXPOSURE TO RADIOFREQUENCY ELECTROMAGNETIC ENERGY IN THE FREQUENCY RANGE FROM 3 KHZ TO 300 GHZ 2. Where exposure is estimated in terms of power density and for exposures shorter than the reference period, power density levels may exceed the reference levels provided that the time average of the power density over any time period equal to the reference period shall

not exceed SRL. For exposures longer than the reference period, including indefinite exposures, the time average of the power density over any time period equal to the reference period

shall not exceed SRL. 3. Spatially non-uniform external field strengths or power density can be spatially averaged, provided the sampling scheme applied ensures that none of the basic restrictions are exceeded at spatially-averaged exposures equal to the reference level. If spatial averaging is not applied, the spatial peak field strength shall be compared to the reference levels. In the case of field strengths, spatial averaging is with respect to the squared values of the field strength samples while for power density, spatial averaging is with respect to the power density samples. 4. For simultaneous exposure to multiple frequencies and where exposure is estimated in terms of power density, each of the power density frequency component amplitudes shall be divided by the corresponding reference level for that frequency, and the sum of all these ratios shall

not exceed unity. This may be expressed as: ∑ (Si/SRL) ≤ 1. 5. For simultaneous exposure to multiple frequencies and where exposure is estimated in terms of field strength, each of the squares of the field strength frequency component amplitudes shall be divided by the square of the corresponding field strength reference level for that frequency, 2 and the sum of all these ratios shall not exceed unity. This may be expressed as ∑ (Ei/ERL) ≤ 1 2 for electric field strength or ∑ (Hi/HRL) ≤ 1 for magnetic field strength. 6. For pulsed RF field exposures estimated in terms of power density, the time-averaged power

density, averaged over any time period equal to the reference period, shall not exceed SRL and the power density, as averaged over the pulse width, shall not exceed 1000 times the reference

level, SRL. 7. For pulsed RF field exposures estimated in terms of field strength, the time average of the squared value of the electric or magnetic field strength over any time period equal to the 2 2 reference period shall not exceed ERL or HRL . In addition, the time average of the squared value of the electric or magnetic field strength, as averaged over the pulse width, shall not 2 2 exceed 1000 times ERL or HRL , respectively. Therefore, the RMS electric or magnetic field

strength, determined over the pulse, shall not exceed 32 times ERL or HRL, respectively.

LIMITS OF HUMAN EXPOSURE TO RADIOFREQUENCY ELECTROMAGNETIC ENERGY IN THE FREQUENCY RANGE FROM 3 KHZ TO 300 GHZ > 9 2.2.3 Induced and Contact Current (3 kHz–110 MHz) Induced current is defined as the current flowing through a single foot to ground in a free-standing body (no contact with conductive objects) exposed to an electric field. Where assessment is made of the current flowing through both feet, the result shall be compared to twice the reference level for a single foot. Contact current is defined as the total current flowing through the body to ground resulting from finger-touch contact with a conductive object insulated from the ground that has been energized in an electric field. Conversely, it can be defined as the total current flowing in an insulated body that has been energized in an electric field and is in finger-touch contact with a grounded conductive object. The current path in the body is from point of touch to ground through the feet. The total current can be assessed anywhere along the path of flow.

TABLE 7: Induced Current Reference Levels

Reference Level (IRL) through a single foot, (mA, RMS) Frequency Reference Uncontrolled Controlled (MHz) Level Basis Environment Environment Reference Period 0.003–0.4 NS 100 ƒ 225 ƒ Instantaneous* 0.4–110 SAR 40 90 6 minutes**

Frequency, ƒ, is in MHz.

TABLE 8: Contact Current Reference Levels

Reference Level (IRL), (MA, RMS) Frequency Reference Uncontrolled Controlled (MHz) Level Basis Environment Environment Reference Period 0.003–0.10 NS 200 ƒ 400 ƒ Instantaneous* 0.1–10 SAR 20 40 Instantaneous* 10–110 SAR 20 40 6 minutes**

Frequency, ƒ, is in MHz.

NOTES FOR TABLES 7 AND 8: 1. * At no point in time shall the RMS values for induced and contact currents exceed the reference levels with an instantaneous reference period in Tables 7 and 8. In the case of currents with amplitude modulation, the RMS value during the maximum of the modulation envelope shall be compared to the reference level. 2. ** For exposures shorter than the reference period, currents may exceed the reference levels, provided that the time average of the squared value of the current over any time period equal 2 to the reference period shall not exceed IRL . For exposures longer than the reference period, including indefinite exposures, the time average of the squared value of the current over any 2 time period equal to the reference period shall not exceed IRL .

10 > LIMITS OF HUMAN EXPOSURE TO RADIOFREQUENCY ELECTROMAGNETIC ENERGY IN THE FREQUENCY RANGE FROM 3 KHZ TO 300 GHZ 3. For simultaneous exposure to multiple frequencies and where comparison is to be made to the reference level based on NS, each of the induced- or contact-current frequency component amplitudes shall be divided by the corresponding reference level for that frequency, and the

sum of all these ratios shall not exceed unity. This may be expressed as ∑ (Ii/IRL) ≤ 1. 4. For simultaneous exposure to multiple frequencies and where comparison is to be made to the reference level based on SAR, each of the squares of the induced- or contact-current frequency component amplitudes shall be divided by the square of the corresponding reference level for that frequency, and the sum of all these ratios shall not exceed unity. This may be expressed 2 as ∑ (Ii/IRL) ≤ 1. 5. For pulsed induced- or contact-currents where a 6 minute reference period applies, the time average of the squared value of the induced- or contact-currents over any time period equal to 2 the reference period shall not exceed IRL . In addition, the time average of the squared value of the induced- or contact-current, as averaged over the pulse width, shall not exceed 1000 times 2 the reference level IRL . Therefore the RMS value of the induced- or contact-current, determined

over the pulse, shall not exceed 32 times the reference level IRL.

LIMITS OF HUMAN EXPOSURE TO RADIOFREQUENCY ELECTROMAGNETIC ENERGY IN THE FREQUENCY RANGE FROM 3 KHZ TO 300 GHZ > 11 ABBREVIATIONS A ampere EEG electroencephalogram

Ei electric field strength frequency component amplitude (RMS)

ERL electric field strength reference level g gram GHz gigahertz

Hi magnetic field strength frequency component amplitude (RMS)

HRL magnetic field strength reference level ICNIRP International Commission on Non-Ionizing Radiation Protection

Ii current frequency component amplitude (RMS)

IRL current reference level kg kilogram kHz kilohertz m meter mA milliampere MHz megahertz mm millimeter NS nerve stimulation RMS root mean square RF radiofrequency SAR specific absorption rate SI International System of Units

Si power density frequency component amplitude

SRL power density reference level V volt W watt

12 > LIMITS OF HUMAN EXPOSURE TO RADIOFREQUENCY ELECTROMAGNETIC ENERGY IN THE FREQUENCY RANGE FROM 3 KHZ TO 300 GHZ DEFINITIONS basic restrictions—Maximum allowable internal electrical quantities in the body, arising from exposure to incident external fields, that prevent the occurrence of all established adverse health effects. contact current—The total current flowing through the body to ground resulting from finger-touch contact with an insulated conductive object that has been energized in an electric field, or from an insulated body that has been energized in an electric field and is in finger-touch contact with a grounded conductive object. controlled environment—An area where the RF field intensities have been adequately characterized by means of measurement or calculation and exposure is incurred by persons who are: aware of the potential for RF field exposure, cognizant of the intensity of the RF fields in their environment, aware of the potential health risks associated with RF field exposure and able to control their risk using mitigation strategies. electric field—A vector quantity assigned to any point in space where the magnitude and direction of the force that would be experienced by a hypothetical test charge, is defined. electromagnetic radiation—A form of energy emitted by accelerating electric charges, that exhibits wave-like behavior as it travels through space. far-field zone—The space beyond an imaginary boundary around an antenna, where the angular field distribution begins to be essentially independent of the distance from the antenna. In this zone, the field has a predominantly plane-wave character. field strength—The magnitude of the electric or magnetic field, normally a root-mean-square (RMS) value. frequency—The number of cycles in the variation of the amplitude of an electromagnetic wave within one second, expressed in units of hertz (Hz). general public—Individuals of all ages, body sizes and varying health status, some of whom may qualify for the conditions defined for the controlled environment in certain situations. induced current—The current flowing through one foot to ground in a free-standing human body (no contact with a conductive object) exposed to an electric field. limbs—Extremities distal from the shoulder and hip joints, which do not include the gonads. magnetic field—A vector quantity assigned to any point in space where the magnitude and direction of the force that would be experienced by a hypothetical test charge-in-motion, is defined. A magnetic field exerts a force on charges only if they are in motion, and charges produce magnetic fields only when they are in motion. near-field zone—A volume of space close to an antenna or other radiating structure, in which the electric and magnetic fields do not have a substantially plane-wave character, but vary considerably from point to point at the same distance from the source. non-thermal effects—Biological effects resulting from exposure to RF fields, that are not due to tissue heating.

LIMITS OF HUMAN EXPOSURE TO RADIOFREQUENCY ELECTROMAGNETIC ENERGY IN THE FREQUENCY RANGE FROM 3 KHZ TO 300 GHZ > 13 power density—The rate of flow of electromagnetic energy per unit area usually expressed in W/m2 or mW/cm2 or μW/cm2. radiofrequency (RF)—A rate of oscillation in the range of about 3 kHz to 300 GHz, which corresponds to the frequency of radio waves typically used in radio communications. reference level—An easily measured or calculated quantity (i.e. externally applied electric field strength, magnetic field strength and power density or resulting body current), that when respected, ensures compliance with the underlying basic restrictions in Safety Code 6. reference period—A time period used for averaging temporally non-uniform RF field exposures, for comparison with the exposure limits in Safety Code 6. The reference periods specified in Safety Code 6 are based upon the established adverse health effects to be avoided and the time required for those responses to occur. The reference period is not a maximum exposure time. RMS (root mean square)—As applied to a set of data, it is the square root of the average of the square of the data values. safety—The absence of established adverse health effects caused by RF field exposure. specific absorption rate (SAR)—A measure of the rate at which energy is absorbed by the body (or a discrete tissue volume) when exposed to a radiofrequency (RF) field. SAR is expressed in units of watts per kilogram (W/kg), and can be calculated from the product of the tissue conductivity (S/m) and the square of the RMS electric field strength induced in the tissue (V/m), divided by the mass density (kg/m3) of the tissue. thermal effects—Biological effects resulting from heating of the whole body or of a localized region due to exposure to RF fields, where a sufficient temperature increase has occurred that results in a physiologically significant effect. uncontrolled environment—An area where any of the criteria defining the controlled environment are not met.

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18 > LIMITS OF HUMAN EXPOSURE TO RADIOFREQUENCY ELECTROMAGNETIC ENERGY IN THE FREQUENCY RANGE FROM 3 KHZ TO 300 GHZ OAKVILLE GREEN DEVELOPMENT – AM RADIO RF ENERGY ASSESSMENT

Appendix B May 8, 2019

APPENDIX B EllisDon Letter, April 18, 2019, 2015

OAKVILLE GREEN DEVELOPMENT – AM RADIO RF ENERGY ASSESSMENT

Appendix C May 8, 2019

Appendix B

A.2 ELLISDON LETTER, APRIL 18, 2019

OAKVILLE GREEN DEVELOPMENT – AM RADIO RF ENERGY ASSESSMENT

Appendix C May 8, 2019

APPENDIX C Preliminary Proposed Building Elevations

OAKVILLE GREEN DEVELOPMENT – AM RADIO RF ENERGY ASSESSMENT

Appendix D May 8, 2019

Appendix C

A.3 PRELIMINARY PROPOSED BUILDING ELEVATIONS

March 1. 2018 Elevations

EAST E Employment Use Hotel + Conference Max Height: 62.5m Max Height: 57.5m 15 Storey 15 Storey

Key Plan

DUNDAS STREET 1 WILLIAM HALTON

Parking PARKING Footing Depth: 9m 3 Levels 2m2m 30m30m 0m0m 10m10m

SOUTH - From Dundas

Medical Employment Use Hotel + Conference Max Height: 63.5m Max Height: 62.5m Max Height: 57.5m 15 Storey 15 Storey 15 Storey S

Key Plan H

THIRD LINE STREET 2

Parking PARKING Footing Depth: 9m 3 Levels 2m 30m 0m 10m March 1. 2018 Elevations

WEST - From Third Line

Medical Max Height: 63.5m Hotel + Conference W Senior Living 15 Storey Max Height: 57.5m Max Height: 49m 15 Storey 15 Storey Key Plan

WILLIAM HALTON STREET 1 DUNDAS

Parking PARKING PARKING Parking Footing Depth: 9m Footing Depth: 9m 3 Levels 3 Levels 2m 30m 0m 10m

NORTH - From William Halton N

Employment Use Medical Max Height: 62.5m Max Height: 63.5m 15 Storey 15 Storey Senior Living Max Height: 49m 15 Storey Key Plan H

STREET 2 THIRD LINE Parking PARKING PARKING Footing Depth: 9m Parking Footing Depth: 9m 2 Levels 3 Levels 2m 30m 0m 10m OAKVILLE GREEN DEVELOPMENT – AM RADIO RF ENERGY ASSESSMENT

Appendix D May 8, 2019

APPENDIX D Toronto AM Stations

OAKVILLE GREEN DEVELOPMENT – AM RADIO RF ENERGY ASSESSMENT

Appendix D May 8, 2019

Appendix D

A.4 TORONTO AM STATIONS

1 2

7 6

4 5

Data Source: First Base Solutions Aerial Flown 2016

LEGEND 1 680 News 4 Newstalk 1010 7 CJRU 1280 AM Figure #1 333 Bloor Street E 250 Richmond St W 55 Gould Street AM Radio Station Sportsnet 590 CHUM TSN 1050 Zoomer Radio AM 740 AM Radio Stations 2 5 8 1000 m Radius 1 Ted Rogers Way 250 Richmond St W 70 Jefferson Avenue Toronto 3 CHTO- AM- 1690 CHIN AM International 437 Danforth Avenue 6 Radio 1540 622 College St PLANNING DATE: April 5, 2019 SCALE 1:40000

north URBAN DESIGN & LANDSCAPE MHBC ARCHITECTURE 230-7050 WESTON ROAD WOODBRIDGE, ON, L4L 8G7 P: 905 761 5588 F: 905 761 5589 | WWW.MHBCPLAN.COM| 5589 761 905 F: 5588 761 905 P: 1 2

Data Source: First Base Solutions Aerial Flown 2016 LEGEND Figure #2 Radio 7 AM 1320 AM Radio Station 1 1900 Dundas Street East AM Radio Stations 1000 m Radius 2 Catholic Radio 820 Mississauga 3615 Dixie Rd Unit 7

PLANNING DATE: April 5, 2019 SCALE 1:40000

north URBAN DESIGN & LANDSCAPE MHBC ARCHITECTURE 230-7050 WESTON ROAD WOODBRIDGE, ON, L4L 8G7 P: 905 761 5588 F: 905 761 5589 | WWW.MHBCPLAN.COM| 5589 761 905 F: 5588 761 905 P: