6 October 2026
The EM Radiation Research Trust (RRT) has submitted detailed reply comments to Innovation, Science and Economic Development Canada (ISED) concerning proposed amendments to Canada’s tower-siting and public consultation process.
The submission responds to ISED’s consultation on the Amendments to the Tower Siting Process and Decision on Roaming, Tower Sharing and Annual Reporting Requirements for Terrestrial Licences (DGSO-001-26).
Receipt of the RRT’s submission has been confirmed by ISED.
Our submission focuses particularly on the proposed modernisation of public consultation, including the move towards a centralised online notification and submission process and the possibility of reducing the consultation period.
Our submission highlights the importance of:
- ◆ Meaningful consultation and sufficient time for residents, municipalities and public representatives to examine proposals;
- ◆ Accessible notification, including consideration for people who may be digitally excluded or require alternative forms of communication;
- ◆ Independent verification of certificates, assessments and technical documentation;
- ◆ Public safety, including fire, electrical and structural safety;
- ◆ Consideration of people with medical implants and those who report electromagnetic sensitivity or other vulnerability;
- ◆ Environmental and cumulative considerations;
- ◆ Local knowledge and community participation; and
- ◆ Transparency and accountability in telecommunications infrastructure decisions.
The submission also places the current Canadian proposals within a wider international and historical context. It draws upon the RRT’s experience of telecommunications planning and public concerns in the United Kingdom, parliamentary debates, scientific literature, legal cases and the Trust’s previous submissions to regulators internationally.
A central theme of our submission is that members of the public should have a genuine opportunity to understand what is being proposed, examine the available evidence, identify questions or concerns, seek appropriate advice and make meaningful representations before decisions are made.
As we state in our submission:
Meaningful consultation requires meaningful time.
The RRT believes that digitalisation can improve communication and access to information, but digitalisation should supplement rather than replace effective public notification and meaningful local participation.
We have made the full submission publicly available so that residents, researchers, public representatives, regulators and other interested parties can read the evidence and arguments presented to ISED.
Read the full submission
Download the RRT Reply Comments to ISED Canada – DGSO-001-26 (PDF):
The RRT will continue to monitor developments concerning the proposed amendments and will make further information available as appropriate.
EM Radiation Research Trust
UK Registered Charity No. 1106304
www.radiationresearch.org