CST News Feed



Oct 1

Please find attached, for service upon BC Hydro, the Plaintiffs' written representations in support of their application to amend. These have been filed with the Court today, October 1, 2015. 

ADDITIONALLY:  Application to Amend


    A. Approach to review of pleadings 
    B. Health concerns 
    C. Personal choice 
    D. Charter overview 
    E. Charter, Section 7 - Liberty Interest 
    F. Charter, Section 7 - Security Interest 
    G. Territorial privacy under the Charter, Section 8 
    H. Biological effects trigger Charter rights 
     I. Pleadings applicable to business premises 
    J. Opt-Out Fees, Failed Installation Fees and Service Refusals 
    K. Fundamental Principles of Justice in Context 
    L. Regulation of Electrical Service in British Columbia 
    M. BC Hydro is exempted from regulation in two respects 
    N. BC Hydro exempted from having to obtain a CPCN 
    O. Fortis not exempted from having to obtain a CPCN 
    P. Direction No. 4 exempts BC Hydro from BCUC scrutiny with respect to its "Meter Choices Program" 
    Q. Customer resistance against BC Hydro's installation of RF-Emitting Meters 
    R. Meter Choices Program 
    S. Direction No. 4 authorizes the mandatory imposition of RF-Emitting Meters 
    T. Customer "choice" & Direct Communication during Election Period 
    U. Duress 
    V. RF-Emitting Meters are not necessary to BC Hydro 
    W. Principles of Fundamental Justice - Overview 
    X. Arbitrariness 
    Y. Overbreadth 
    Z. Gross disproportion 
    AA. Lack of parity 
    BB. Lack of democratic process 
    CC. Duress 
    DD. Each element of the cause of action is supported by pleadings of fact 
    EE. The test for determining whether the pleadings disclose a cause of action 


    A. Proposed classes
    B. The test for "identifiable class"
    C. Rational relationship as between (1) the criteria for class membership;
    and (2) the claims advanced on behalf of that class
    D. Rational relationship as between (1) the criteria for class membership;
    and (2) the common issues pertaining to that class
    E. Remaining test elements met


    A. Legal standard
    B. Proposed common issues
    C. Additional common issue and a methodology for determining "reasonableness"
    D. Potential reformulations: the Customer's express position is not material
    E. Application of the test
    F. Variables within a class


    A. Legal test

    B. Whether questions of fact or law common to the members of the

    class predominate over any questions affecting only individual members

    C. Whether a significant number of the members of the class have a valid interest individually controlling the prosecution of separate actions

    D. Whether the class proceeding would involve claims that are or have been

    the subject of any other proceedings

    i. BCUC Exemption by way of the CEA
    ii. BCUC Exemption by way of Direction No. 4
    iii. Consequence of exemption
    iv. Human Rights Complaint

E. Whether other means of resolving the claims are less practical or less efficient

    i. Overview
    ii. The practicalities and efficiencies of class proceedings
    iii. There is a large number of individual claimants, each with a relatively
    small claim for monetary relief
    iv. Expert evidence will be required to resolve the dispute as to whether
    there is a reasonable basis for concern about health risk

F. Whether the administration of the class proceeding would create greater difficulties

than those likely to be experienced if relief were sought by other means

G. Certification fulfills the advantage of access to justice

H. Certification fulfills the advantage of judicial economy

I. Certification fulfills the advantage of behaviour modification

J. Summary of preferability inquiry


A. Legal test

B. Each representative plaintiff would fairly and adequately represent the

interests of his or her respective class

    i. Overview
    ii. Davis and O'Connor as representatives of Class A
    iii. Klein and Halani as representatives of Class B
    iv. Schnurr and Noble as representatives of Class C
    v. Competence of class counsel
    vi. Ability to bear any necessary costs
    vii. Conclusion

C. The representative plaintiffs have produced a plan for the proceeding that

sets out a workable method of advancing the proceeding on behalf of the

respective classes and of notifying class members of the proceeding

D. The representative plaintiffs do not have, on the common issues, an

interest that is in conflict with the interests of other class members



    Schedule A - Assertions of Health Concerns
    Schedule B - Reasonableness of Health Concerns
    Schedule C - Health Canada's Cellular Telephone Advice
    Schedule D - Contested issues will involve competing expert evidence
    Schedule E - Forced installations
    Schedule F - Forced installations - Commercial
    Schedule G - Direction No. 4 and Meter Choices Program
    Schedule H - Direct Communication
    Schedule I - Meter Choices Participation Statistics
    Schedule J - Eligible Customers who refuse to pay (with the consequence that they
    suffer a Forced Installation or a Service Refusal, threatened or actual) e.g. Sylvester
    Schedule K - Eligible Customers who capitulate to the installation of an RF-Emitting
    Meter - e.g. Schnurr
    Schedule L - Eligible Customers who pay an opt out fee to avoid installation of an RF Emitting Meter
    Schedule M - BC Hydro can operate without RF-Emitting Meters
    Schedule N - Quantity of claimants
    Schedule O - Independent claimants without alternative recourse
    Schedule P - Representative plaintiffs' motivations
    Schedule Q - Representative plaintiffs are informed
    Schedule R - BCUC proceedings re: CEA exception
    Schedule S - Human Rights Tribunal Complaint
    Schedule T - Fortis 1 (Universal Opt-outs)
    Schedule U - Fortis 2 - Quantum of Opt-out Fee
    Schedule V - BCUC re: BC Hydro Fees
    Schedule W - July 23, 2013. BCUC Fortis decision, excerpted

Oct 1

CLASS ACTION: Plaintiffs Written Representations - Application to Amend

(October 1, 2015) In the Supreme Court of British Columbia Between: Nomi Davis and Jessica Klein (Plaintiffs) and British Columbia Hydro and Power Authority (Defendant)

Please find attached, for service upon BC Hydro, the Plaintiffs' written representations in support of their application for certification. These have been filed with the Court today, October 1, 2015.

ADDITIONALLY: Application for Certification 


A. Orders sought
B. Facts

  1. Defined terms
  2. Direction 4
  3. Impact on the Plaintiffs' case
  4. Reformulated claim
  5. Additional facts
C. Jurisprudence
D. Prejudice to BC Hydro?
E. The Province of British Columbia
F. Rules of Court

Sep 28

First US Public School District Limits Wi-Fi Radiation Exposure to Students and Staff

Ashland, Massachusetts Public Schools have implemented Wi-Fi Device "Best Practices" which include turning the Wi-Fi off when not in use and keeping devices on a table.

" . . . Based on its own review of the matter, the Ashland Public School District is reducing wireless radiation exposures to children by instituting district wide "best practices for mobile devices". Spurred by parent Cecelia Doucette's concerns about the lack of safety data on Wi-Fi and children, the district investigated the issue and developed a policy to substantially reduce wireless exposures to students and staff. Doucette not only brought the issue to the district's attention, but then also worked with state legislatures who introduced two bills concerning electromagnetic radiation this session. The Environmental Health Trust submitted written testimony on MA Senate Bill 1222 after expert scientists presented information on wireless health risks at a briefing at the Massachusetts State House in June 2015.

"Since wireless devices are constantly emitting radiation even when the user is not using the Internet, the instruction to "turn it off when not in use " stops the Wi-Fi antennas from continuously emitting radiation and is one simple way to reduce the radiation dose and exposure time for children and staff. . . .

"This ground breaking policy action by the Massachusetts school district is indicative of the wave of parents raising concerns about Wi-Fi across the country. Ashland, Massachusetts parent Cecelia Doucette wrote an article in Ashland Local Town Pages about these new best practices. Significant news and print media have picked the issue up after Massachusetts parents filed a lawsuit against a private boarding school alleging the school did not accommodate their 12-year-old child's diagnosed debilitating sensitivity to the school's WiFi system.

"Ashland is the first US public school to create such policy on wireless transmitting devices. However, this US Massachusetts school district now joins dozens of schools and governments that have already implemented even more stringent measures to reduce wireless exposure to children. For example, Israel and France have banned Wi-Fi in kindergarten. The European Union recommends wired Internet rather than wireless in schools.

"Right To Know" efforts by local governments are also moving across the United States. . . .

Sep 14

FCC Maximum Permissible Exposure Limits

for Electrogmagnetic Radiation, as Applicable to Smart Meters - Ronald M. Powell, Ph.D.

  • History 
  • Current FCC Maximum Permissible Exposure Limits 
  • Interpretation of the Tables
  • Discussion of Examples of Permitted Exposure Levels 
  • Peak versus Average Exposure Levels 
  • Thermal versus Non-Thermal Effects on Humans 
  • Applying the FCC Exposure Limits 
  • Legal Presentation of the FCC Exposure Limits

Sep 12

Candidates Who Care (Canadian Federal Election)

C4ST - Do YOUR Riding's Candidates Care?

In June 2015 the Conservatives, Liberals, and NDP on the Parliamentary Health Committee unanimously voted to educate and protect Canadians from the growing concern around wireless radiation.  

Does your candidate care?

We are asking all candidates running for Member of Parliament, if elected, to agree to support efforts to work with Health Canada and other appropriate agencies and organizations to:

• Develop an awareness campaign relating to the safe use of wireless technologies, such as cell phones and Wi-Fi, in key environments such as the school and home. (see official HESA recommendation)
• Investigate, and potentially adopt, measures taken in other countries to limit the exposure of vulnerable populations, including infants, and young children in the school environment to radiofrequencies. (see official HESA recommendation)
• Improve the testing, diagnosis, treatment and data collection regarding electromagnetic hypersensitivity and its possible impact on health in the workplace. (see official HESA recommendation)
• Establish a system to report potential adverse reactions to radiofrequency fields. (see official HESA recommendation)  



Aug 31



This resolution is intended to address the concerns of citizens regarding the escalating growth of wireless radiation in British Columbia. We invite the signatures of medical health professionals and researchers who wish to join with us in bringing attention to the hazards of electromagnetic radiation. 

Hello Fellow Citizens:

As citizens of British Columbia, we have created a British Columbia Resolution on the Proliferation of Electromagnetic Radiation and we are requesting your support. The resolution is at the address below. http://petitions.moveon.org/sign/the-british-columbia-1

The purpose of the resolution is to force our Provincial Health Officer Dr. Perry Kendall to take action to implement the precautionary principle...rather than continuing on his current course of willful blindness and denial. It will ultimately be delivered to the British Columbia Provincial Health Office.

We are seeking the signatures of medical and other health professionals as well as all concerned citizens. Beneath the signature panel there is space to add comments... your comments are especially useful to us and welcomed.

We request your consideration towards signing our resolution. If you know of others that may be interested in supporting this initiative, we would appreciate you forwarding this email to them.

Thank you for your time, and good luck in fighting this fight that we must win...at any cost.

Ron Gordon Maple Ridge BC

"When injustice becomes institutionalized, resistance becomes a duty."


Whereas the population of the Province of British Columbia is not currently protected by effective and authoritative guidelines or regulations governing exposure to involuntary or incidental, non-thermal, electromagnetic radiation in their homes and public places, the British Columbia, Canada, organization - Citizens for Safe Technology - in collaboration with the undersigned, hereby passes the following Resolution. 


  1. Guidelines and regulations to protect the population of British Columbia from the effects of all forms, frequencies and intensities of electromagnetic radiation must be immediately instituted. 
  2. The guidelines and regulations mentioned in Article 1 must be based on the findings of independent, non industry-affiliated studies which include, but are not limited to, research into the effects of low-level, non-thermal pulsed radiation; (1) 
  3. The Provincial Health Officer for British Columbia must publicly acknowledge and immediately invoke the Precautionary Principle (2) with regards to the protection of the population of the Province of British Columbia against the known and/or potential harmful acute and chronic effects of exposure to all forms, frequencies and intensities of electromagnetic radiation; and 
  4. Direct and immediate action must be taken to halt the proliferation of, and subsequently reduce, the non-consensual exposure of children and pregnant mothers to electromagnetic radiation in all areas of society, most notably through the removal of wireless internet connections in schools, libraries, and other public places.

Aug 31

PETITION - No Electromagnetic Warfare Testing on the Olympic Peninsula!

West Coast Action Alliance - To call attention to the effects of war games over the sacred and beautiful land of the Olympic National Park (reposted from February, 2015)

This area includes the last remaining temperate rainforest in all of North America. It is the quietest region in the country. Eight tribal nations, hundreds of thousands of residents live here, and more than 3 million people come to visit each year. . . .

This is a wonderful confluence of WiFighters helping each other.
Please support them by signing their PETITION
This testing is happening all over the US, so we need to get good at fighting this.

Aug 23

Letters to Fay School Trustees re Wi-Fi in Schools (Massachusetts)

Dr. David O. Carpenter, Martin Blank Ph.D., Dr. Stephen T. Sinatra, Professor Olle Johansson

The Fay Board of Trustees received these four letters from scientific experts in electromagnetic fields. They have been submitted to "Wi-Fi in School ADA Federal Complaint Against School After Child Fell Sick From Wireless Installation."  

Breaking: 8/12/2015
Federal complaint seeks injunctive relief for violation of the Americans with Disabilities Act and damages for breach of contract and negligence.  PRELIMINARY INJUNCTION

Aug 1

Prove-It / TRACK-IT

Website with opportunities to participate in solutions

Jul 25

Federal Petition - C4ST

Create a Mechanism for Canadians to Report Adverse Reactions to Wireless Radiation

"The Standing Committee of Health (2010) report . . . obtained recommended that:

"Health Canada ensure that it has a process in place to receive and respond to reports of adverse reactions to electromagnetic radiation emitting devices.

"In this document obtained by C4ST under the Access to Information Act, the memo from Health Canada to the Minister of Health states: "HC does not support the recommendation to establish an adverse reaction reporting process specifically for RF exposures."

"Help us encourage Health Minister Ambrose to follow the Parliamentary Committee recommendations by gathering signatures on the below petition to be presented in the House of Commons.


Wireless Radiation Reporting - House of Commons Sitting 209 (English)
Published on 22 Jun 2015

First reading of the petition in the House of Commons by MP Alex Atamanenko:

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Citizens for Safe Technology (CST) is funded and supported solely by those who wish to help us. Thank-you for learning, sharing and helping if you can.

Meetings and events on the issue of wireless technologies in homes and communities throughout North America.

Click the button above to sign our online petition to return to hardwired computers in schools.

Click the button above to sign our online petition against Smart Meters in British Columbia.

Smart Meter Petition (Hard Copy)

Download and print this petition form -- Refuse Smart Meter Installation.

Send completed petitions 15 signatures per page to:
Una St. Clair


e-mail: una@citizensforsafetechnology.org