2614 Otter Point Road - Freedom Mobile Telecommunication Tower

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1 2614 Otter Point Road - Freedom Mobile Telecommunication Tower RECOMMENDATION: THAT COUNCIL discuss the report provided by Cypress Land Services, on behalf of Freedom Mobile and provide a recommendation as to referral comments to Freedom Mobile and Industry Canada in relation to the proposed telecommunication tower at 2614 Otter Point Road. Report Summary: The proponent, Cypress Land Services on behalf of Freedom Mobile has presented a report to address the concerns received by phone, and at the Committee of the Whole meeting that was held on June 19, 2017 in regards to the proposed 50-metre Freedom Mobile monopole tower locating at 2614 Otter Point Road Previous Council Action: Recommendations from June 19, 2017 Committee of the Whole meeting: THAT Freedom Mobile compile and address concerns from the Committee of the Whole and the community in a package to staff, regarding the proposed telecommunication tower at 2614 Otter Point Road; AND THAT a report be brought forward to a future Regular Council Meeting. Attached Documents: Freedom Mobile Report to Council Staff report to June 19 COW meeting Development Services Regular Council - September 11, RPT File No

2 Report to District of Sooke Council and Staff Summarizing and Detailing the Public Consultation Process of Freedom Mobile Telecommunication Site: BVI0089A Tawny Verigin, Municipal Affairs Specialist August 22, 2017

3 Executive Summary This report is in response to a recommendation from District of Sooke Committee of the Whole ( COW ) meeting held on June 19, The COW recommended: THAT Freedom Mobile compile and address concerns from the Committee and the community in a package to staff, regarding the proposed telecommunication tower at 2614 Otter Point Road; AND THAT a report be brought forward to the July 10, 2017 Regular Council Meeting. The only concern raised with regard to this proposed wireless installation was that of health and safety. This concern was raised by one member of the community and a few Committee members. As indicated at the Committee meeting, the proposed site far exceeds regulations established within Health Canada s Safety Code 6 to ensure public safety. Compliance with the limits of Safety Code 6 are the only applicable exposure limits in Canada. Freedom Mobile s proposed site BVI0089A in Sooke, BC has been calculated to have a ground level (2m above ground) of 0.1% of Safety Code 6 or 1000 times lower than the prescribed limits in an uncontrolled environment (public exposure). Further to the above, below is a summary of the proposed site as it may relate to concerns raised: The site is fully compliant within the maximum exposure limits established in Health Canada s Safety Code 6 for controlled environment; The site is fully compliant within the maximum exposure limits established in Health Canada s Safety Code 6 for uncontrolled environment; The site meets the technical target coverage objectives for the Freedom network; The location is well setback (95m) from Otter Point Road to minimize visibility of the pole; The sightlines of the tower are significantly minimized by the existing tree cover; Industry Canada s Report on the National Antenna Tower Policy states research does not indicate a correlation between property value and tower location; and The addition of the proposed site and the launch of Freedom Mobile s network in the greater Victoria area (including Sooke) will provide an additional choice for wireless consumers with access to lower rates/flexible contracts. Freedom Mobile looks forward to launching its network in the area with the support of the District of Sooke. We kindly request District Staff and Council consider the information in this report and provide a recommendation of Concurrence to ISED and the proponent, Freedom Mobile, as it pertains to the proposal BVI0089A. Page 2 of 13

4 To: CC: RE: Address: District of Sooke Municipal Council Tara Johnson, Planner II Development Services Department Freedom Mobile Inc. Report to District of Sooke Staff & Council 2614 Otter Point Road, Sooke, BC Legal: PID: Coordinates: N , W Freedom Mobile Site: BVI0089A Purpose This report responds to a recommendation from District of Sooke Committee of the Whole ( COW ) that Freedom Mobile Inc. ( Freedom ) compile and address concerns from the Committee and the community in a package to staff, regarding the proposed telecommunications tower at 2614 Otter Point Road. Request That the District of Sooke Council through the Development Services Department provide a recommendation of Concurrence for the proposed Freedom Mobile site BVI0089A at 2614 Otter Point Road to the Spectrum Management branch of Innovation, Science and Economic Development Canada ( ISED formerly Industry Canada) and to the proponent Freedom Mobile. Background Freedom has emerged as Canada s fourth national wireless services provider, a truly Canadian company, owned and operated by Shaw Communications. In the efforts to provide a competitive mobile offering to Canadian consumers, Freedom is in the process of launching improved 3G and LTE network coverage in multiple markets across Canada. Specifically, in this case, Freedom has proposed a new wireless mobile base station installed on a new tower on the south side of the property at 2614 Otter Point Road, Sooke, B.C. (Schedule A: Tower Site Location) in order to fill in coverage along Sooke Rd between approved site BVI0090A and proposed tower site BVI0047F (Schedule B: Coverage Map). This proposal will enable Freedom to provide continuous coverage to customers in the Sooke area within a distance of a few kilometres. To leave this coverage area unaddressed is to entirely defeat the purpose Page 3 of 13

5 of a mobile network. The benefit of continuous mobile coverage is that customers receive reliable access to voice, text and data (broadband) services as the end user moves freely through the network. Further to the obvious convenience of these services, it also provides peace of mind to Freedom customers knowing they have immediate access to emergency services. As a federal undertaking, Freedom is required by ISED to consult with land-use authorities in siting new wireless mobile base station tower locations. The consultation process established under ISED s authority is intended to provide the local land-use authorities an opportunity to address land-use concerns while respecting the federal government s exclusive jurisdiction in the siting and operation of wireless voice and data systems. In proposing the mobile base station tower BVI0089A, Cypress Land Services Inc. on behalf of Freedom has undertaken the land-use and public consultation process as described in the District of Sooke Policy 11.4 Communications Antenna Policy. Beginning in April 2017, this process has consisted of submissions detailing the proposed development to the District planning department, as well as public consultation via mailed notification to surrounding property owners within three times the tower height (150.0 metres) and a public notice placed in the local newspaper and presentations/public input at the Committee of the Whole meeting that was held June 19, This report summarizes and documents all Committee, community and staff input received to date, and provides detailed responses to questions and concerns raised. Committee, Public & Staff Comments The following section is a generalized report on the input received to date. Through the comments at the Committee of the Whole, the objection is related to the perceived (negative) health effects. For a detailed list of the individual comments and responses please see the attached chart (Schedule C: Comments and Concerns). Health Effects Risk Assessment vs. Risk Perception A common theme emerged in the comments heard from the public at the Committee of the Whole Meeting on June 19, 2017 as well as from the responses received to date. Cypress Land Services Inc. received one comment of support, and one comment of non-support. Both were responded to in writing. The District of Sooke received two comments of non-support. The concern identified in these comments of non-support is that wireless mobile base stations Page 4 of 13

6 installed on towers or more colloquially cell towers pose a significant threat to the health and well-being of Canadians and specifically to those that live in close proximity to them. Mobile wireless base stations installed on towers cell towers transmit and receive radiofrequency (RF) signals or energy in order to connect with the nearby cell phones and other mobile devices in the network. RF energy from cell towers is a form of non-ionizing radiation, which means it is not strong enough to break chemical bonds. Common sources of RF exposure include cell phones, cordless telephones, FM radio transmitters, baby monitors, Wi-Fi routers and of course, cell towers. Most countries set exposure limits for RF at a national level. In Canada, the Ministry of Innovation, Science and Economic Development Canada ( ISED formerly Industry Canada) have adopted Health Canada s Limits of Human Exposure to Radiofrequency Electromagnetic Energy in the Frequency Range from 3kHz to 300 GHz (Safety Code 6 [2015]) Health Canada s RF exposure guidelines. Ongoing compliance with Safety Code 6 is a mandatory condition of all Canadian wireless carriers. The exposure limits set in Safety Code 6 are based on an ongoing review of published peer reviewed scientific studies, including both internal and external authoritative reviews of the scientific literature, as well as Health Canada s own research. The code is periodically revised to reflect new knowledge in the scientific literature. The current version of Safety Code 6 was updated in 2015 and replaces the previous version published in Health Canada reminds all Canadians that their health is protected from radiofrequency fields by the human exposure limits recommended in Safety Code 6. Health Canada has established and maintains a general public exposure limit that incorporates a wide safety margin and is therefore far below the threshold for potentially adverse health effects. Health Canada continues to monitor and analyze scientific research on this issue and should new scientific evidence arise demonstrating that exposure to radiofrequency fields poses a health risk to Canadians, Health Canada will take the appropriate action to safeguard the health of Canadians. Despite Health Canada s (and external agencies WHO, ICNIRP, Royal Society of Canada) conclusion that as long as cell towers respect the limits set in Safety Code 6 there is no scientific reason to consider towers dangerous to the public many members of the public often raise the issue of health concerns where a new cell tower has been proposed. Often these are the most emotional comments/concerns raised by the public and are the most challenging of antenna related issues to address. In making decisions about potentially hazardous technologies, scientists and government policy makers employ a sophisticated risk assessment analysis of cell tower and cell phone technology, whereas members of the public tend to rely on their own intuitive judgement about hazards called risk perception. Risk perceptions are usually based on media reports, information and opinions found on the internet, the opinions of family members, friends and other members of the community. The theory of risk perception would suggest that based on Page 5 of 13

7 current media and internet information many members of the public would perceive RF exposure from cell towers as being a high-risk technology. The reason this is commonly perceived as a high-risk activity/technology by the public is that: Low personal control over the risky activity (members of the public have little control over where these facilities are proposed and needed); Worst possible consequences are perceived (cancer, DNA damage, etc.); The risk is not assumed voluntarily (they did not ask for the cell tower or purposefully move near one, despite the ubiquity of cell sites located in almost every community); Unfamiliar with the risky activity/technology (RF engineering is a specialized discipline); A perceived risk for children or others who might believe they are more sensitive. This risk perception is contrasted with risk assessment. The risk assessment is based on an independent examination of the most current peer-reviewed scientific studies available. The risk assessment is done principally by the scientists working in the radiation branch of Health Canada. Based on the analysis of the risk assessments completed, Health Canada has created RF exposure standards. The limits in Safety Code 6 are science-based exposure limits that are consistent with the sciencebased standards used in other parts of the world, including the United States, the European Union, Japan, Australia and New Zealand. Large safety margins have been incorporated into these limits to provide a significant level of protection for the general public and personnel working near RF sources. Internationally, a few jurisdictions (cities, provinces or countries) have applied more restrictive limits for RF field exposures from cell towers, although Health Canada maintains there is no scientific basis to support the need for such restrictive limits. Additionally, in many instances these more restrictive limits are not applied to other wireless devices in these same jurisdictions. Limits in Canada, the United States and most Western European countries (and many in other parts of the world) follow the Institute of Electrical and Electronics Engineers (IEEE) standard C or the similar International Commission on Non-Ionizing Radiation Protection (ICNIRP) limits (Safety Code 6 limits are comparable) While the Russian Federation, China, Switzerland and a few other countries have limits as much as 100 times lower some of these lower limits are science-based while others are precautionary based. Page 6 of 13

8 Country / Regulation Limit for general public exposure to RF (2000 MHz) for extended periods of exposure, W/m2 Percentage of Safety Code 6 International Commission on % Non-Ionizing Radiation Protection (ICNIRP) FCC (U.S.) % Safety Code 6 10 The Canadian Standard China 0.1 1% Russia 0.1 1% Typical max. exposure from base station % BVI0089A With respect to the micro-wave antenna, it is clear that its contribution will not exceed 5.5% of the Safety Code 6 uncontrolled limit directly in its main beam from the antenna to 11 m in front of it. The analysis shows that at 2m above the highlighted existing building rooftop, the RF signal does not exceed 1% of the uncontrolled environment limit. The Russian and Chinese (and many Eastern European) limits reflect the idea that long-term exposure at levels below western limits result in adverse health effects. Russian and Eastern European literature does contain reports of health-effects from low-level exposure to RF energy (Chinese reports contain similar information) including references to a microwave disease however, this disease is not recognized in Western medicine and its diagnostic criteria is considered by many vague and non-falsifiable (unscientific). Further, many of the Russian research reports lack crucial information (e.g. frequencies, intensity of exposure, SAR, description of experimental design) Western health agencies and standard setting bodies generally only consider studies that meet minimum standards reporting and methodology likely many Russian and Eastern European studies would be excluded from consideration or given very little weight in the Western risk assessment process due to serious flaws and inadequate documentation. Italy, Switzerland and a few other countries have recently adopted exposure limits that are based on precautionary measures. Unlike the science-based limits (which are designed to avoid identified hazards) these precautionary limits were designed to minimize the yet unknown risks of RF exposure. Page 7 of 13

9 Regarding the precautionary principle the World Health Organization (WHO) recommends precautionary principle be adopted only under the condition that scientific assessments of risk and science-based exposure limits should not be undermined by the adoption of arbitrary cautionary approaches. That would occur, for example, if limit values were lowered to levels that bear no relationship to the established hazards or have inappropriate arbitrary adjustments to the limit values to account for the extent of scientific uncertainty. While compliance with the limits of Safety Code 6 are the only applicable exposure limits in Canada, Freedom Mobile s proposed site BVI0089A in Sooke, BC has been calculated to have a ground level (2m above ground) 0.1% of Safety Code 6 or 1000 times lower than the prescribed limits in an uncontrolled environment (public exposure). Exposure levels at ground level may be substantially lower as the simulation tool is not well suited to calculating levels below 0.1% as well it does not account for any objects that may attenuate exposure in the environment (e.g. trees, buildings). Final Result The site is compliant with the maximum exposure limits established in Health Canada s Safety Code 6 for uncontrolled environment. The site is compliant with the maximum exposure limits established in Health Canada s Safety Code 6 for controlled environment. Please see Schedule D: Safety Code-6 Analysis for specific details. Network Benefits & the Freedom of Choice Subjective information from revised pricing offers of the incumbent cell phone service providers is that when Freedom Mobile (formerly WIND Mobile) came into the marketplace in 2009/2010 across Canada, consumers began to save between ten and fifteen percent off of their billing. Now, as the fourth national cell phone provider, this value to consumers continues. As we are in the process of planning and acquisition efforts on the South Island on Vancouver Island, this benefit will soon extend to the island communities and consumers. It may be true that the neighbors to this proposed cell tower have acceptable service from their phones however, this service is not being provided by Freedom as our network is not yet built and launched. The addition of a fourth national carrier to the Canadian wireless market provides increased choice for consumers. Freedom proudly offers lower rates for families students and small business. As well, Freedom provides local and regional employment. Freedom currently employs 1,275 people in Canada. As Freedom increases their customer base, more retail and service jobs are created. Page 8 of 13

10 Conclusion Wireless mobile base station towers or cell towers are now commonplace in the Canadian and worldwide landscape. In order to provide the benefits of wireless services to consumers this infrastructure is required. As illustrated by Canadians demand and consumption of wireless services (voice, text and data services) it does not appear wireless infrastructure development and improvements will be slowing down any time soon. Although objections have been raised by some members of the community to this development we maintain that it is the best possible solution to fill the gap in Freedom Mobile s planned network; The site meets the technical target coverage objectives for the Freedom network. The site as proposed is setback 95m from Otter Point Road; Sightlines of the tower are significantly minimized by the existing tree cover; The addition of site BVI0089A and the launch of the Freedom Mobile network on Vancouver Island and in Sooke will provide an additional choice for wireless consumers in the area - the benefits of which will apply to new customers (lower rate plans, flexible contracts) also provides potential benefits to existing wireless users who may experience reduced rates in response to Freedom s launch. Cypress Land Services Inc. on behalf of Freedom Mobile have completed the consultation procedures as required under ISED and District of Sooke policies. As such, we kindly request District Staff and Council consider the information in this report and provide a recommendation of Concurrence to ISED and the proponent Freedom Mobile as it pertains to the proposal BVI0089A. Best regards, Sincerely, Tawny Verigin Cypress Land Services Inc. Municipal Affairs Specialist Page 9 of 13

11 Proposed monopole Location SCHEDULE A - TOWER SITE LOCATION

12 Page 11 of 13 SCHEDULE B COVERAGE MAP

13 SCHEDULE C: COMMENTS AND CONCERNS

14 Name of Resident Address Phone Date Message Received , Letter, Comment Sheet or Voice Message Comment or Question Comments & Responses Tracker BVI0089A Support / nonsupport / Response to Comment or Question neutral Date Response Sent Neil Harvey nharv33@gmail.com 24 May Hello support Dear Mr. Harvey, 30 May Can you tell me the coverage for this proposed tower. I live at the junction of West Coast Rd and Otter Point rd. Currently there is no cell service from anyone at this location. Thanks Neil Harvey Thank you for providing us your comments regarding the proposed Freedom Mobile wireless communications facility on Kemp Lake Road. This site is intended to provide wireless coverage to portions of the local area within a radius of a few kilometers to service residents, business, travelling public and emergency responders. We appreciate your feedback and will share your feedback with the Juan de Fuca Local Area Services staff to consider. Should you have any further questions or concerns, please do not hesitate to contact us. Sincerely, Cypress Land Services Inc. Agents for Freedom Mobile Tawny Verigin Municipal Affairs Specialist Wayne Jolly 2625 Otter Point Rd cedarcot@telus.net 08 Jun phone call Wayne Jolly called to express his opposition. He has health concerns and would like to know where the other sites are located. non support Good afternoon Wayne, Thank you for calling to provide us your comments regarding the proposed monopole at 2614 Otter Point Road, Sooke, BC. 14 Jun You asked where the other sites in Sooke are located. Please find a map attached. BVI0053 : 6726 Eustace Road Rooftop site at the Legion BVI Butler Road, Sooke tower site BVI Otter Point Rd, Sooke 50m monopole BVI Kemp Lake Rd, Juan de Fuca 45m monopole The proposed tower location is in compliance with the Canadian Environmental Assessment Act and to the best of our knowledge, this is not an environmentally sensitive area. You expressed concerns of health impacts. Please know Freedom Mobile relies on experts to set standards for safety. In Canada, Health Canada has established Safety Code 6 to ensure public safety. Safety Code 6 was updated in 2015 based on all credible science in this field done around the world. It is considered by Health Canada to be current and valid for protecting the health and safety of all Canadians. The limits specified in Health Canada s RF exposure guidelines are based upon review of thousands of peer reviewed scientific studies of the health impacts of RF energy. SC6 take into consideration the existing EMF energy and the calculations are cumulative to include all surrounding local sites. Telecommunication operators propose to locate antennas where service is needed providing access to 911 and other telecom services in areas that don t currently have them. As long as the site conforms to SC6, there is no cause for alarm. RF energy from the proposed tower will be several hundreds times lower than the limit set by SC6. Should you have further questions regarding the research behind Safety Code 6 regulation or the regulation itself, we encourage those in the community to contact Heath Canada at: ccrpb pcrpcc@hc sc.gc.ca. We appreciate your feedback and will share it with the District of Sooke to consider. Should you have any further questions or concerns, please do not hesitate to contact us. Wayne Jolly 2625 Otter Point Rd cedarcot@telus.net 16 Jun Thanks Tawny for your reply. Will you be at the meeting in Sooke Monday? Sincerely, Cypress Land Services Inc. Agents for Freedom Mobile Tawny Verigin Municipal Affairs Specialist Greetings Mr. Jolley, 05 Jul One point in your mail out about Health Canada Safety code 6, saying it is one of the most stringent in the world, I believe is absolutely false and misleading. Canada, USA and Australia have exposure limits that are 100 x s higher than China, Italy, Russia and Poland and 1000 x s higher than Bulgaria, Austria and many other countries. Thank you for your additional comments regarding the proposed monopole at 2614 Otter Point Road, Sooke, BC. In consideration of your concern regarding exposure to radio frequency (RF) energy, Freedom Mobile has completed a predictive Safety Code 6 Analysis in accordance with the Health Canada standards, which is attached for your reference. I hope you will correct this in future mail outs as it very misleading and gives people a false sense of safety and security, when in fact these cell towers actually could pose severe risks to their health. In searching the internet it is very clear to me that health Canada hasn t listened to the abundant research indicating the possibility of severe health risk to communities and families in close proximity to cell towers (500 metres) There are many mountain tops in the Sooke area that are free from habitation and this is where Shaw s towers should be built, even though it might require higher developer costs they could save on site rental costs. Telecommunications companies like Shaw clearly know that they are putting communities health at risk with these towers. How many deaths, how many illnesses are they responsible for? Slowly our world has to change into a place where people, even corporations, have to learn to care for each other and take the precautionary principal to heart. It is definitely promising to see so many countries taking the lead but sad to see how far Canada and companies like Shaw are lagging behind. Best regards, Wayne In summary, the analysis states that on the ground or at any existing building rooftops on the property, the RF signal from the cellular antennas does not exceed 1% of the uncontrolled or controlled environment limit. Based on the findings, the safety code 6 analysis concludes that the site is compliant and in fact is one one hundredth of the limit for RF that is set by Health Canada. These results are calculated assuming a person roughly 2.0 metres in height would be standing at ground level or on the rooftop of any building on the property. RF EMF energy levels diminish exponentially as you move further away from the antennas including locations off of the owners property on which this tower is proposed. With respect to the microwave antenna, it is clear that its contribution will not exceed 5.5% of the Safety Code 6 uncontrolled limit directly at its main beam from the antenna to 11m in front of it. This type of antenna send its EMF directly in a line to the next nearest location in the Freedom network. Of course no one from the public would be expected to be directly 11m in front of the microwave dish at its proposed height of 48m mounted on the tower above the ground level. The EMF from this dish at ground level will be negligible. Should you have further questions regarding the research behind Safety Code 6 standards or the regulation itself, we encourage those in the community to contact Heath Canada at: ccrpb pcrpcc@hc sc.gc.ca. In your , you suggested Freedom Mobile should locate the tower on one of the mountain tops in the Sooke area that are free from habitation. Please know that in order to properly service communities, antenna installations need to be located near where people are using wireless services. This proposed installation is required to be in an area that fits in with Freedom Mobile s overall network plan. This site is intended to provide wireless coverage to portions of the local area within a few kilometres to service residents, tourists, business, travelling public and emergency responders. When a telecommunications carrier is determining a location for new wireless installation it must consider a number of factors to ensure the new installation operates effectively to result in improved wireless services for the immediate community. Some of the considerations include the allocated frequency of operation as issued by then Industry Canada, the local topography, the patterns of wireless users, the surrounding building heights, the road patterns, the availability of land or existing structures. Many households rely on wireless service as their only means of communication to meet their personal, business and emergency needs. Wireless antenna installations, such as the one proposed, are commonly located within close proximity to where people live and work such as in communities across greater Victoria on the South Island and in

15 Name of Resident Address Phone Date Message Received , Letter, Comment Sheet or Voice Message Comment or Question Comments & Responses Tracker BVI0089A Support / nonsupport / Response to Comment or Question neutral y p y p p g Vancouver including placement on hospitals, universities, and residential buildings. Date Response Sent We appreciate your feedback and will share our response with the District of Sooke for their further consideration. Should you have any additional questions or concerns, please feel free to contact us. Sincerely, Michael J. Walker Gordon P. Friesen Shirley F. Walker Christina F. Friesen 15 Jun Sent to District of Sooke District of Sooke 2225 Otter Point Road Attn: Committee of the Whole non support Cypress Land Services Inc. Agents for Freedom Mobile Tawny Verigin M i i laff i S i li t N/A Re: Intent to Erect a Communications Tower at 2614 Otter Point Road We wish to submit out objection to the proposed application scheduled for consideration at the Committee of the Whole meeting on June 19th. We are owners of the adjacent property at 2640 Otter Point Road (Lot 27) and are very concerned. There is scientific evidence to support the dangers of these communications towers and our ultimate concern is for the health and safety of the community. Approving this application will result in diminished values of surrounding properties, an additional hardship for owners. Respectfully, Michael J. Walker Gordon P. Friesen Shirley F. Walker Christina F. Friesen Michael J. Walker Gordon P. Friesen Shirley F. Walker Christina F. Friesen 24 Jul Sent to District of Sooke District of Sooke 2225 Otter Point Road July 24, 2017 non support N/A Dear Mayor Tait & Councillors Re: Intent to Erect a Communications Tower at 2614 Otter Point Road We are owners of the adjacent property at 2640 Otter Point Road (Lot 27) and are writing in regard to the attached July 22nd Times Colonist article "Sooke rejects cellphone tower" stating that "Another application for a tower at Otter Point Road is still under consideration". Following the July 10th Council Meeting, we find this news article disturbing and disappointing as the same concerns apply to both applications and it was our belief that we would be supported as well. Residents at both location have provided detailed documentation based on current research, and concern for the impact this issue has on residents and neighbours was voiced by some members of Council. At the 5154 Sooke Road location, "About 20 nearby residents said they had issues with the proposed tower..." please consider the number of people who are living in the trailer park directly across the road. Attached are copies of our letters to the Committee of the Whole and, as recommended to Randall Garrison, MP. Please reject the application at 2614 Otter Point Road as well. Respectfully Michael J. Walker Gordon P. Friesen Shirley F. Walker Christina F. Friesen

16 Name of Resident Address Phone Date Message Received Janie Jolley 2625 Otter Point Road, Sooke, BC , Letter, Comment Sheet or Voice Message 19 Jun Sent to District of Sooke Comment or Question Comments & Responses Tracker BVI0089A Committee of the Whole.District of Sooke Re Proposed Freedom Cell Antenna at 2614 Otter Point Road, Sooke BC non support For COW Meeting June 19, Sooke Council Chambers Please include this in your package of information for this meeting. Sooke landowners are being tempted by Freedom Mobile to place antenna on their property..$15,000 a year. They are reassured that by Health Canada standards they are safe. However research has proven that you need to be 500 metres from towers not 150 metres as stated in Health Canada guidelines. The RF radiation is constant not like that of other devices that can be turned off. Many neighbourhoods in our community are dealing with applications for cell towers, however you only get notified of meetings or opportunity for input if you are within 150 metres of the proposed antenna. We rely on Health Canada to keep us safe from radiation from these towers with their guidelines. Having done some research these guidelines are not strict enough to keep us safe. We need to be 500 metres away. Our Canadian standards are some of the lowest in the world! Hard to believe but true. Having recently visited a friend from years ago, she was looking much older and frail and we found out she is suffering from EHS..electro hyper sensitivity or Rapid Aging Syndrome due to RF( radio frequency ) radiation. We had never heard of it! We then get a letter in the mail re a cell antenna application in our neighbourhood. Did some research and realize it is proven that RF radiation is a class 2B carcinogen (World Health Organization) and others. RF radiation is harmful and we must listen and stand up for our health, that of our children and our neighbours. Colwood's Mayor is now listening to Triangle Mountain residents who have health issues from all of the antennae and Oak Bay residents are signing petitions to try and get antennae in safe locations. Besides health issues the value of properties in many areas has decreased due to nearby antennas. And if you agree to an antenna or tower on your property you can be sued for damages to others!! Also hard to believe! We must all do research and educate ourselves about RF radiation. The danger is proven and we must listen. (Dr. Magda Havas, Trent University, international expert and Scientific Advisor ) Even if you are waiting for Health Canada to change their guidelines why would you put your family and your neighbours at risk of RF radiation illnesses? Or if you are the land owner of the property why would you put yourself at risk of law suits in the future. We need to change the bylaws in Sooke and our neighbouring communities and educate everyone about the dangers of RF radiation. New cell towers are being applied for so that companies can extend their business and make money. It is not necessarily about better service for us. It is putting our health at risk. We are fortunate to live in a rural area where there is land for such towers that would be a greater distance than 500 metres from our homes, schools and community. Thanks for the opportunity to give this feedback. Cell towers in our backyards are not safe! We need updated bylaws to protect us as well as newer guidelines for the safety of our health. Janie Jolley 2625 Otter Point Road, Sooke BC. Support / nonsupport / Response to Comment or Question neutral N/A Date Response Sent

17 Page 13 of 13 SCHEDULE D: SAFETY CODE-6 ANALYSIS

18 Safety Code-6 Analysis Freedom Mobile 3G & LTE Network Radio frequency exposure for uncontrolled and controlled environment Freedom Mobile 207 Queen's Quay West, Suite 710 Toronto, ON M5J 1A Otter Pt Rd, Sooke, BC [BVI0089] Lat: Long: New site Existing site Colocations Author Eli Amey, ing. jr (#OIQ : ) Supervisor Joseph Sadoun, ing. (#OIQ : ) Yves R. Hamel et Associés inc Guy, Montreal, QC Tel Fax Project: P The site is compliant (uncontrolled environment) The site is compliant (controlled environment) The site is non-compliant (both environments) Safety Code-6 Analysis Freedom Mobile 3G & LTE Network JS

19 [BVI0089-2] Site Description (1 of 2) The site BVI0089 is located at 2614 Otter Pt Rd, Sooke, BC. It is a 50 m tower on which a number of Freedom Mobile antennas are installed. These antennas are shown on the drawings and their operating parameters are presented in the tables shown on pages 4 and 5. Freedom Mobile sectors 1, 2 & 3 antennas are installed on the tower. Access to the tower is restricted by fences and locked. The site is therefore a controlled environment. Freedom Mobile Comment: Yves R. Hamel et Associés inc Guy, Montreal, QC Tel Fax Project: P Safety Code-6 Analysis Freedom Mobile 3G & LTE Network

20 [BVI0089-3] Site Description (2 of 2) Comment: Yves R. Hamel et Associés inc Guy, Montreal, QC Tel Fax Project: P Safety Code-6 Analysis Freedom Mobile 3G & LTE Network

21 [BVI0089-4] Antenna listing (1 of 6) Freedom Mobile Comment: Yves R. Hamel et Associés inc Guy, Montreal, QC Tel Fax Project: P Safety Code-6 Analysis Freedom Mobile 3G & LTE Network

22 [BVI0089-5] Antenna listing (6 of 6) Microwave antennas (Freedom Mobile) Yves R. Hamel et Associés inc Guy, Montreal, QC Tel Fax Project: P Comment: The cellular antennas will be further analysed in the following pages. With respect to the micro-wave antenna, it is clear that its contribution will not exceed 5.5% of the Safety Code 6 uncontrolled limit directly in its main beam from the antenna to 11 m in front of it. Hence this antenna needs no further evaluation. Safety Code-6 Analysis Freedom Mobile 3G & LTE Network

23 [BVI0089-6] Site Overview Freedom Mobile Sector 3 Freedom Mobile Sector 1 Freedom Mobile Sector 2 [All Sector] Comment: Yves R. Hamel et Associés inc Guy, Montreal, QC Tel Fax Project: P Safety Code-6 Analysis Freedom Mobile 3G & LTE Network

24 [BVI0089-7] RF simulation for uncontrolled environment 2m above the first existing building rooftop. N Yves R. Hamel et Associés inc Guy, Montreal, QC Tel Fax Project: P Comment: The analysis shows that at 2m above the highlighted existing building rooftop, the RF signal does not exceed 1% of the uncontrolled environment limit. Safety Code-6 Analysis Freedom Mobile 3G & LTE Network [All Sector]

25 [BVI0089-8] RF simulation for uncontrolled environment 2m above the second existing building rooftop. N Yves R. Hamel et Associés inc Guy, Montreal, QC Tel Fax Project: P Comment: The analysis shows that at 2m above the highlighted existing building rooftop, the RF signal does not exceed 1% of the uncontrolled environment limit. Safety Code-6 Analysis Freedom Mobile 3G & LTE Network [All Sector]

26 [BVI0089-9] RF simulation for uncontrolled environment 2m above ground. N Yves R. Hamel et Associés inc Guy, Montreal, QC Tel Fax Project: P Comment: The analysis shows that at 2m above ground, the RF signal doesn t exceed 1% of the uncontrolled environment limit. Safety Code-6 Analysis Freedom Mobile 3G & LTE Network [All Sector]

27 [BVI ] RF simulation for uncontrolled environment 3D (1 of 2) [West view] Comment: Yves R. Hamel et Associés inc Guy, Montreal, QC Tel Fax Project: P Safety Code-6 Analysis Freedom Mobile 3G & LTE Network

28 [BVI ] RF simulation for uncontrolled environment 3D (2 of 2) [East view] Comment: Yves R. Hamel et Associés inc Guy, Montreal, QC Tel Fax Project: P Safety Code-6 Analysis Freedom Mobile 3G & LTE Network

29 [BVI ] RF simulation result Uncontrolled environment The safety code 6 analysis shows that the site is compliant to the uncontrolled environment limit 2 m above ground and surrounding buildings. The RF signal does not exceed 1% of the uncontrolled environment limit. Controlled environment The safety code 6 analysis shows that the site is compliant to the controlled environment limits 2m above the 2 existing building rooftops where levels do not exceed 1% of the limits. General action required MOVE ANTENNA(S) (RELOCATE ANTENNA AND/OR MOUNT) INSTALL WARNING SIGNS AROUND NON COMPLIANT ANTENNA LOCK/MARK ACCESS POINT AT ENTRANCE AND INSTALL CAUTION SIGN ADJUST ANTENNA ORIENTATION (RE-AZIMUTH OR UP-TILT) ATTENUATE OR SHUTDOWN ANTENNA(S) OR SECTOR(S) This site is compliant uncontrolled/controlled. Yves R. Hamel et Associés inc Guy, Montreal, QC Tel Fax Project: P Safety Code-6 Analysis Freedom Mobile 3G & LTE Network

30 [BVI ] Site compliance (1 of 2) N NO WORST CONTRIBUTOR IDENTIFIED % Worst contributor ( uncontrolled / controlled environment ) - No worst contributor identified. [All Sector] - The site is compliant to the uncontrolled environment limits 2m above any accessible surface with levels remaining below 1% of the uncontrolled environment limit. Comment: This site is compliant uncontrolled/controlled. Yves R. Hamel et Associés inc Guy, Montreal, QC Tel Fax Project: P Safety Code-6 Analysis Freedom Mobile 3G & LTE Network

31 [BVI ] Site compliance (2 of 2) Freedom mobile maximum RF exposure Maximum exposure on this site for uncontrolled environment : 1 % Final result The site is compliant with the maximum exposure limits established in Health Canada s Safety Code 6 for uncontrolled environment. The site is compliant with the maximum exposure limits established in Health Canada s Safety Code 6 for controlled environment. The site is non-compliant with the maximum exposure limits established in Health Canada s Safety Code 6 for both environments. I hereby certify that this report was completed using appropriated methods; that the information contained herein is exact to the best of our knowledge and that compliance with Safety Code 6 limits in each section of the site is as described above. Author Eli Amey, ing. jr (#OIQ : ) Supervisor Joseph Sadoun, ing. (#OIQ : ) Yves R. Hamel et Associés inc Guy, Montreal, QC Tel Fax Project: P Safety Code-6 Analysis Freedom Mobile 3G & LTE Network JS

32 [BVI ] Additional explanations on Safety Code 6 (1 of 3) Safety code 6 Health Canada publishes a document called Safety Code 6 where the limits of human exposure to RF energy are detailed, for frequencies between 3 khz and 300 GHz. The exposure limits specified in Safety Code 6 have been established based upon a thorough evaluation of scientific literature related to thermal and non-thermal effects of RF fields, using a weight-of-evidence approach. The limits in Safety Code 6 are based on the lowest exposure levels at which any scientifically established adverse health effect occur. Furthermore, safety margins are incorporated into these exposure limits to ensure that even the worst-case exposure remain far below the established thresholds. Finally, the scientific approach used to establish the exposure limits in Safety Code 6 is comparable to that employed by other science-based international bodies such as the World Health Organisation (WHO) or the International Commission for Non Ionising Radiation Protection (ICNIRP) Safety Code 6 limits are set for two types of environments, called Controlled and Uncontrolled environment. These two types of environments are defined as follows: Controlled Environment: An area where the RF field intensities have been adequately characterised by means of measurements or calculations 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. Uncontrolled Environment: An area where any of the criteria defining the controlled environment are not met. For this analysis we will use the Uncontrolled Environment standard for all normally accessible areas such as ground or rooftop around the site while Controlled Environment standard will be used for areas accessible only to qualified workers such as the tower. The standard used in this report is based on the most recent Safety Code recommendations. The figure below illustrates the power density limits for Controlled and Uncontrolled Environments for the 2015 standards. Furthermore, all our results are expressed as a percentage of Safety Code 6 limits, which is the usual representation for multi-frequency environments. In this representation, all values below 100% represent exposures compliant with Safety Code 6 limits while values above 100% represent exposures exceeding those limits. Comment: Yves R. Hamel et Associés inc Guy, Montreal, QC Tel Fax Project: P Safety Code-6 Analysis Freedom Mobile 3G & LTE Network

33 [BVI ] Additional explanations on Safety Code 6 (2 of 3) References UCE 2015 CE 2015 The analysis and the resulting document have been prepared in compliance with the applicable reference documents: Safety Code 6 (2015) «Limits of Human Exposure to Radiofrequency Electromagnetic Energy in the Frequency Range from 3 khz to 300 GHz» Health Canada GL-01 «Guidelines for the Measurement of Radio Frequency Fields at Frequencies from 3 khz to 300 GHz» Industry Canada GL-8 «Guidelines for the Preparation of Radio Frequency (RF) Exposure Compliance Reports for Radio communication and Broadcasting Antenna Systems» Industry Canada CPC «Radio Frequency (RF) Fields Signs and Access Control» Industry Canada Comment: Yves R. Hamel et Associés inc Guy, Montreal, QC Tel Fax Project: P Safety Code-6 Analysis Freedom Mobile 3G & LTE Network

34 [BVI ] Additional explanations on Safety Code 6 (3 of 3) Microwave antennas The accepted approach for microwave parabolic antennas is to consider these antennas as radiating the entirety of their energy in a well-defined beam and not contributing to the levels of RF energy present outside of this beam. Therefore, the only consideration regarding a parabolic reflector is to avoid worker presence in front of the reflectors. Cellular and mobile radio antennas This type of antennas is represented using the Visual EMF or IXUS software. These tools simulate the distribution of energy in the near and far field of the antenna and give with great precision the area where exposure levels exceed Health Canada (Safety Code 6) levels. Broadcast antennas Broadcast antennas are analysed using a separate simulation tool, designed specifically to 1 rue the complexities of large, high-power antennas. This approach uses the antennas horizontal and vertical radiation patterns, frequency, ERP and individual radiating element patterns and location to simulate a realistic power density distribution around each of the radiating elements. Comment: Yves R. Hamel et Associés inc Guy, Montreal, QC Tel Fax Project: P Safety Code-6 Analysis Freedom Mobile 3G & LTE Network

35 [BVI ] Possible software used for simulation The simulation is performed by constructing a three-dimensional model of the site and then adding all transmitting antennas. Some antenna models are provided with the software, others had to be created from the radiation patterns that may be available on Industry Canada or on manufacturers web sites. Antenna characteristics, such as frequency, radiated power and position are then entered into the software. The simulation then gives a representation of the radiation for each antenna and the size of the zones which require restricted access. The study only simulates the propagation of the signal free space and does not consider the surrounding obstacles or the absorption of the signal by these obstacles. A tree attenuates the signal by a factor of 4 to 5 times, while a wall attenuates the signal by a factor of at least 10 times. In short, we are only simulating the worst case. The simulation may show higher field levels than there would be in reality since the simulation always uses maximum power parameters ant considers all antennas as operating simultaneously. Comment: Yves R. Hamel et Associés inc Guy, Montreal, QC Tel Fax Project: P Safety Code-6 Analysis Freedom Mobile 3G & LTE Network

36 2614 Otter Point Road - Freedom Mobile Telecommunication Tower RECOMMENDATION: THAT Committee of the Whole provide a recommendation to Council as to referral comments to Freedom Mobile and Industry Canada in relation to a proposed telecommunication tower at 2614 Otter Point Road. Report Summary: Freedom Mobile has submitted the attached Information Package to locate a 50.0-meter monopole telecommunication tower at 2614 Otter Point Road, with the intent to provide improved wireless voice and data coverage for the community that is within a few kilometers of the proposed location. Under the Radiocommunication Act, Industry Canada has exclusive jurisdiction in the licensing of Antenna Systems, but proponents must consult with the local land use authority and the public. The feedback provided to Industry Canada from the community will be weighed in the decision-making process. Report: Industry Canada's Radiocommunication Act outlines the process that must be followed by proponents seeking to install or modify Antenna Systems. As the Federal Regulator for Antenna Systems, Industry Canada requires the proponents to consult with local government and the local community within a prescribed distance of the proposed Antenna structure. The District of Sooke Communications Antenna Policy states that any recommendations provided by the Committee of the WHole will be forwarded to Council, which will then be forwarded to Industry Canada and the proponent. The agent for Freedom Mobile has stated that there are no structures of adequate height and in the vicinity of where Freedom requires a site that they can collocate on. The closest tower is owned by TELUS and is approximately 1.5 km SW. The agent for Freedom Mobile has stated that the TELUS tower is located too far from the area that Freedom Mobile intends to service so it will not work for their network requirements. Sooke Zoning Bylaw, 2013 (Zoning Bylaw) The proposed location of 2614 Otter Point Road is zoned Rural Residential (RU4). The Zoning Bylaw addresses antenna systems in two ways. Section 3.12(a) states that there is no height restriction for antenna or federally regulated communication towers provided that the structure occupies no more than 5% of the lot and Section 3.19(a) states that communication towers and antennas are exempt from setback requirements. The proposed tower will not occupy more than 5% of the lot and will therefore meet all Zoning Bylaw requirements. Development Services Committee of the Whole - June 19, RPT File No

37 Sooke Official Community Plan, 2010 (OCP) The proposed communication tower is located within the Sooke Community Growth Area and is on property designated as Community Residential (CR). The CR designation is an area within which low to medium density residential growth will occur along with some associated and appropriately scaled commercial development. Legal Impacts: The proponent has notified owners and occupants of properties within 150 meters of the proposed tower and has advertised the proposed antenna system, as well as the date and time of the Committee of the Whole meeting in two consecutive issue of the Sooke News Mirror and the Sooke Voice News. As per the Sooke Communications Antenna Policy, the District has notified owners and occupants of properties within 100 meters of the proposed tower location of the Committee of the Whole meeting. As per Industry Canada, the ultimate role of the municipality is to issue a statement of concurrence or non-concurrence to the proponent and to Industry Canada. Attached Documents: 2614 Otter Point Rd_Subject_Property_Map Communications Antenna Policy No. 11.4, Otter Pt tower proposal industry canada - radiocommunication and broadcasting antenna systems Development Services Committee of the Whole - June 19, RPT File No

38 SUBJECT PROPERTY MAP 2 B A 2665 B A 2659 A File: 2614 Otter Point Rd B PT OTTER POINT ROAD A #1 #2 9 #8 #5 #6 #9 #10 #11 PT #3 #4 #7 LARONDE ROAD A 2587 PT 8 B 2586 A BURR DRIVE 6807 PETEMAR ROAD B Subject Area Metres

39 Policy 11.4 September 9, 2002 Communications Antenna Policy Policy Statement: 1. This policy applies to telecommunication carriers (antennae) subject to Industry Canada Policy CPC This policy does not include residential T.V. antennae, satellite dishes, small antennae affixed to buildings, or amateur ham radios. 2. The objective of this policy is to encourage dialogue between the applicant and the District of Sooke with respect to the location, height and output of communication antennae and their associated structures so as to ensure that such structures fit with the form and character of the surrounding area. 3. The applicant must consult with the Development Services Department prior to construction of the structure. 4. The applicant must submit for discussion purposes the following: a. Expected time of construction b. Plans indicating size, location and type of antenna structure proposed. 5. The Municipal Planner shall prepare a report to the Committee of the Whole regarding the proposed development. 6. Owners and tenants in occupation of each parcel that is within 100 metres of the subject site must be notified of the Committee of the Whole meeting. 7. The recommendations of the Committee of the Whole shall be forwarded to Council. 8. The Development Services Department shall forward Council s comments and recommendations concerning the application to the Federal Agency (Industry Canada) and the applicant.

40 Cypress Land Services Telephone: Suite Granville Street Facsimile: Vancouver, BC V6Z 1G3 Website : April 19, 2017 Via tjohnson@sooke.ca Tara Johnson, Planner District of Sooke 2205 Otter Point Road Sooke, BC V9Z 1J2 Dear Ms. Johnson: Subject: Freedom Mobile Telecommunications Facility Proposal Information Package Address: 2614 Otter Point Road, Sooke, BC Legal: PID: Coordinates: N , W Freedom Mobile Site: BVI0089A Overview Cypress Land Services, in our capacity as agent to Freedom Mobile, is submitting this information package to formalize the consultation process related to the installation and operation of a telecommunications facility. We have been in preliminary consultation with the District of Sooke regarding the installation. Freedom Mobile plans to launch its wireless services in the greater Victoria area and is proposing this installation in order to provide dependable wireless data and voice communication within portions of Sooke. This information package is intended to formalize the consultation process. Proposed Site The subject property is located at 2614 Otter Point Rd in Sooke, BC. The property is zoned RU4 and consists of a few outbuildings. The installation consists of a monopole, 50.0 metres in height, with three (3) flush mounted antennas and two (2) microwave antennas. The equipment compound will be located at the base of the monopole and enclosed by a chain-link fence. Please see Schedule A: Tower Site Location.

41 Rationale for Site Selection Freedom Mobile seeks to provide high quality, dependable wireless communications services through the launch of its network. When a telecommunications carrier is determining a location for a new wireless installation it must consider a number of factors to ensure the new installation operates effectively and results in reliable wireless services for the immediate community. Some of the considerations include frequency of operation, local topography, patterns of wireless users, building heights, road patterns, availability of land and existing structures. Freedom Mobile reviewed collocation options on nearby tower sites and unfortunately there are no nearby towers able to accommodate Freedom Mobile s equipment. Availability of a willing property owner is a major consideration; Freedom Mobile has entered into a long-term agreement with the property owner to permit the installation. Tower Proposal Details A slim line monopole design with flush mounted panel antennas is proposed in order to create a monopole with minimal visual impact and is set back from Otter Point Road behind some trees that will screen a portion of the structure. Freedom Mobile has completed preliminary design plans (Schedule B: Preliminary Plans) as well as photo-simulations (Schedule C: Photosimulations). These preliminary design plans are subject to final engineered design, land survey and approval of Transport Canada. Transport Canada approval may require tower lighting and/or marking. The photo-simulations area for conceptual purposes only. Freedom Mobile encourages any preliminary comments from the District of Sooke and the community. Consultation Process with the District of Sooke The proposed telecommunications installation is subject to the consultation processes outlined in the District of Sooke s Communications Antenna Policy. The policy applies to telecommunication carriers (antennae) subject to Innovation, Science and Economic Development Canada (ISED), (formerly Industry Canada) Policy CPC The process also includes a report to the Committee of the Whole regarding the proposed development, where owners and tenants in occupation of each parcel that is within 100 metres of the subject site must be notified of the Committee of the Whole meeting. To comply with the ISED process, we would like to recommend that the notification radius be extended to 150 metres (three times the tower height) in order to cover duplicate notification requirements. Freedom Mobile Site: BVI0089A Page 2 of 7

42 The recommendations of the Committee of the Whole shall be forwarded to Council and Council s comments and recommendations concerning the application to the Federal Agency (ISED) and the applicant. Health and Safety Health Canada s Safety Code 6 regulations are applicable to this, and all, telecommunications sites. Safety Code 6 seeks to limit the public s exposure to radiofrequency electromagnetic fields and ensures public safety. Additional information on health and safety may be found on-line at: Health Canada: Concurrence Requirements In order to complete the consultation process, Freedom Mobile will be requesting concurrence from the District of Sooke in a form acceptable to both the District of Sooke and to ISED. We understand that, subsequent to the required public consultation process and a Council decision, the District of Sooke would be providing a letter of resolution. Conclusion Please consider this information package as the official commencement of the District of Sooke s Communications Antenna Policy. Freedom Mobile is committed to working with the District of Sooke and the community in determining an appropriate location and design for a telecommunications tower that will provide wireless communication services. We look forward to working together during this process. Please do not hesitate to contact us by phone at or by at tawny@cypresslandservices.com. Thank you in advance for your assistance and consideration. Sincerely, CYPRESS LAND SERVICES Agents for Freedom Mobile Tawny Verigin Municipal Affairs Specialist cc: Ryan McKeown, Real Estate Supervisor, Freedom Mobile Freedom Mobile Site: BVI0089A Page 3 of 7

43 SCHEDULE A - TOWER SITE LOCATION Proposed monopole Location Freedom Mobile Site: BVI0089A Page 4 of 7

44 SCHEDULE B PRELIMINARY PLAN COMPOUND PLAN Freedom Mobile Site: BVI0089A Page 5 of 7

45 SCHEDULE B PRELIMINARY PLAN TOWER PROFILE Freedom Mobile Site: BVI0089A Page 6 of 7

46 SCHEDULE C PHOTO-SIMULATIONS View: Looking southwest from Otter Point Road Freedom Mobile Site: BVI0089A Page 7 of 7

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