Yasuko Kato, Association Director VOC-EMF Measures Research

January 29, 2011

Yasuko Kato

Journalist

VOC-EMF Measures Research

Association, Director

471, Bankei, Chuou-ku,

Sapporo, Hokkaido,

064-0945 JAPAN

Comment on CCST Smart Meter report

I am a journalist and a director of a self-help group for Multiple Chemical Sensitivity (MCS) and Electromagnetic Hyper Sensitivity (EHS) in Japan. I am also a patient of MCS and EHS. So, I have been working to improve the environment for sensitivity people and vulnerable children.

The smart grid program is planning all over the world including Japan. In our country, Smart Meters have installed in some area, and other utilities are planning to install it as demonstratively experiment. So, I have interested in Smart Meter issues in California and CCST report.

Why did not show the major factors?

CCST expressed the RF level was 40?W/cm2 at 3 feet from Smart Meter. But, CCST did not show the important factors related to this calculation, such as a number of meters, an assumed environmental, and reflection of building materials.

FCC limit never provide safety

FCC limits that based on thermal effects never provide safety to general people. Many studies have been described the adverse health effect occurred by non-thermal effects under the limit of International Commission of Non-Ionizing Radiation Protection (ICNIRP) that is same to FCC. The Bioinitiative Report mentioned “the body of evidence at hand suggests that bioeffects and health impacts can and do occur at exquisitely low exposure levels: levels that can be thousands of times below public safety limits“ and recommended the value of 0.1 ?W/cm2 for RF. This value is ten thousand times below FCC limits.

Why did not CCST describe about EHS ?

There is an important EHS article by P. Levallois et al. (2002). They estimated the prevalence of self-reported sensitivity to EMF was 3.2%, with 24.4% of those surveyed reporting sensitivity to chemicals, in California. It was necessary to have forecast the adverse health effect at the early stage of the smart grid program. In actually, many people have been already claimed many symptoms by Radio Frequency (RF) emission from PG&E Smart Meters. CCST have to seriously consider these claims.

The rights of person with EHS

I carried out a questionnaire survey in 2009 about health problem, economical, and social issues related to EHS in Japan. The valid responses were only 75, however the total cost to avoid EMF, such as moving to low EMF area, RF shielding reconstruction and replacing to low emission household appliances, reached to about 168 million yen (about1.8 million US dollars). Fifty-three percent had a job before the EHS onset, but 65% of them lost their work or experienced a decrease in income. Major symptoms were “fatigue/tiredness”(85%), and “headache”, “difficulty of concentrating, remembering and thinking” (81%, respectively) . Sixty five percent indicated they experienced symptoms attributable to radiation from other passengers’ mobile phones abroad public transportation, and12.0% said they could not use any public transportation due to their serious symptoms. The survey indicated EHS people are significantly limited their daily life due to EMF exposure.

EHS and MCS are publicly recognized as disabilities in U.S.A. under the ADA. Federal Register (Sept. 3, 2002) mentioned “ The (Architectural and Transportation Barriers Compliance) board recognizes that multiple chemical sensitivities and electromagnetic sensitivities may be considered disabilities under the ADA if they are so severely impair the neurological, respiratory or other functions of an individual that it substantially limits one or more the individual’s major life activities.”

In 2005, National Institute of Building Science (NIBS) published the report “Indoor Environmental Quality (IEQ) ” in according with the request from the Architectural and Transportation Barriers Compliance Board.

IEQ report mentioned ;

“For people who are electromagnetically sensitive, the presence of cell phones and towers, portable telephones, computers, fluorescent lighting, unshielded transformers and wiring, battery re-chargers, wireless devices, security and scanning equipment, microwave ovens, electric ranges and numerous other electrical appliances can make a buildings inaccessible.”

Then, they established the recommendations to increase the access for sensitivity people. It includes;

?Cell Phones Turned off

? Ability to turn off or unplug computers and other electrical equipment by occupant or staff

? Ability to turn off fluorescent lighting by occupant or staff

“ The focus of the project was on commercial and public buildings, but many of the issues addressed and recommendations offered in residential settings”.

However, the radiation from Smart Meters is making the harmful environmental that EHS people can’t access to their house. Moreover, EHS people will increase more and more due to RF radiation from Smart Meters. It might cause economical huge damage of California. The radiation is also affect to vulnerable people, such as children and elderly people. CCST have to stand on precautional principle, and to recommend to replace wired meters from wireless Smart Meters, as soon as possible.

References;

P. Levallois, .R.Neutra, G. Lee and L. Histova, Study of self reported hypersensitivity to electromagnetic fields in California, Environ. Health. Perspect. 110(4) (2002) 619-623

Bioinitiative Report: A rationale for a Biollogicaly-based Public Exposure Standard for Electromagnetic Fields ( ELF and RF)

Federal Register Vo;.67, No. 170/Tuesday, September 3, 2002/ Eiles and Regulations

National Institute of Buildings Sciences, “IEQ Indoor Environmental Quality”  (2005)

Karl Maret, MD

Commentary on the California Council on Science and Technology Report

“Health Impacts of Radio Frequency from Smart Meters”

By Dr. Karl Maret

Dove Health Alliance, Aptos, CA

January 30, 2011

This is a commentary on the California Council on Science and Technology (CCST)report, “Health Impacts of Radio Frequency from Smart Meters” published January 2011. I submit that the CCST report, written in response to health concerns expressed by Assembly Members of the California Legislature, contains inaccuracies and minimizes the biological effects and health impacts of non-thermal radiofrequency radiation, such as those produced by wireless technologies including Smart Meters.

For the record, my qualifications to make this commentary are that I hold a Bachelor of Science in Electrical Engineering, a Master of Engineering degree in Biomedical Engineering, and a Medical Doctor degree and have additionally completed a four year post-doctoral fellowship in physiology.  I have been interested in the health effects of electromagnetic fields (EMFs) for many years and given lectures about the potential health impacts of non-ionizing radiations, both in Europe and the United States.  I am president of a non-profit foundation interested in energy medicine, a sub-specialty within the field of Complementary and Alternative Medicine (CAM) as defined by the National Center for Complementary and Alternative Medicine (NCCAM), a center within the U.S. National Institutes of Health (NIH).

My specific concerns with the report are as follows:

  1. The minimization of the problem of non-thermal microwave radiation;
  2. The minimization of the need for lower exposure standards;
  3. The increase in radiation levels at potential local hotspots through reflection;
  4. The lack of information about the impact of pulsed radiation from Smart Meters;
  5. The lack of information on the health impacts of night-time radiation from Smart Meters;
  6. The lack of modeling or actual measurements of the contribution from Smart Meters to the existing background microwave radiation;
  7. The lack of health and environmental consideration by the CPUC when the Advanced Metering Infrastructure (AMI) was approved.

Until these issues are more fully addressed it is recommended that the current Smart Meter deployment using radiofrequency radiation (RFR) be halted pending a more unbiased reassessment of the potential health issues associated with these meters, including a reassessment of the Advanced Metering Infrastructure (AMI) program approved by the California Public Utilities Commission (CPUC) without any environmental impact assessment.  Further, that the California public be offered the option to opt out of this program, which at present is mandatory for every dwelling.

1. Minimization of Non-thermal Microwave Radiation from Smart Meters

On page 4 of the CCST report it states that “To date, scientific studies have not identified or confirmed negative health effects from potential non-thermal impacts of RF emissions such as those produced by existing household electronic devices or smart meters.” This finding minimizes the extensive body of scientific research on the biological effects of non-thermal electromagnetic fields.  The biological effects of low-level, non-thermal electromagnetic fields have been researched for over 30 years.  Therespected 2007Handbook ofBiological Effects of Electromagnetic Fields edited by Barnes and Greenebaum (1) states on page 377:

The biophysical lore prevailing until the late 1980s and lingering to this day is that, unless the amplitude and frequencies of an applied electric field were sufficient to trigger an excitable membrane (e.g. heart pacemaker), produce tissue heating or move an ion along a field gradient, there could be no effect.  …. However, this position had to be changed as the evidence for weak (non-thermal) EMF bioeffects became overwhelming.”

Prof. Arthur Pilla, PhD
Professor of Biomedical Engineering, Columbia University

There are numerous reports on the potential health effects of non-thermal electromagnetic fields.  Early reports include papers by Frey (1993), Lai (2000) and  Hyland (2000), among many others.  An international working group has delineated many additional scientific findings (Bioinitiative report, 2007).  Special editions of the journal Pathophysiology were specifically dedicated to this topic recently (Pathophysiology, 2009).  Recently, the European Journal of Oncology published an entire monograph entitled “Non?Thermal Effects and Mechanisms of Interaction between ElectromagneticFields and Living Matter” outlining non-thermal effects on living systems.  This came from the National Institute for the Study and Control of Cancer and Environmental Diseases “Bernardino Mamazzini” (Giuliani &Soffriti, 2010).

The CCST report further states that, “Without a clearer understanding of the biological mechanisms involved, identifying additional standards or evaluating the relative costs and benefits of those standards cannot be determined at this time.” I strongly disagree with this conclusion as there is now a large body of scientific literature describing several key mechanisms for the action of weak electromagnetic fields.  These include, among others:

-          removal of calcium ions bound to cellular membranes, leading to their weakened structure and changed cellular functioning

-          change of calcium ion leading to changes in metabolic processes in cells,

-     the leakage of calcium ions into neurons generating spurious action potentials,

-     fragmentation of DNA in cells seen through the Comet assay

-     changes in the blood-brain barrier in animals after microwave exposure

-     defined cellular stress response, including the production of  heat shock proteins (HSP), that are triggeredelectromagnetically at non-thermal levels that require much less energy than when triggered by heat (so-called thermal considerations)

-     activation of specific genes by exposure to non-thermal electromagnetic fields leading to gene transcriptionto form RNA, the first stage in the synthesis of proteins

All these biological effects are well substantiated in the scientific literature and occurred at much lower exposure levels than current FCC standards, but are minimized by the CCST report.  It takes many years for definitive health effects to be substantiated beyond all shadow of doubt.  Yet the evidence is accumulating that health effects will become more widespread, given sufficient time, from thescientifically researched biological responses to RFR.  Until the authors of the CCST report can clearly substantiate their conclusions that the California population will not be adversely affected by the Smart Meter program, a precautionary approach should have been recommended.

The European community has been more concerned about non-thermal radio frequency radiation effects while our government has essentially stopped funding all research in this area (see below).  The extensive REFLEX study involving research groups from seven countries found effects on biological systems from cell phone radiation at levels 1/40th of the level of accepted safety guidelines promulgated by the International Commission on Non-Ionizing Radiation Protection (ICNIRP) (Adlkofer, 2006).   This report focused on a four year international collaborationof twelve European research groups involving in vitro studies of non-thermal radiofrequency radiation from cell phones.  Even Austrian insurance companies are now accepting the dangers from non-thermal electromagnetic radiation from cell phones (AUVA Report, 2009).

Biological systems often respond in a non-linear manner and there is a large degree of genetic variability as to how animals or people are affected.  Non-thermal EMFs might be comparable to the hazards of low levels of toxins found in the environment which can be potent in very low levels at disrupting enzyme systems in the body, but may not be proportionately worse at higher levels.

Dr. Richard Gautier in France offered a full description of active mechanisms for the action of non-thermal EMFs.   There are peer-reviewed scientific studies for each step of the processes that can lead to chronic diseases such as cancer, leukemia and neurological diseases.  These conditions often require longer time periods to develop and the Precautionary Principle (see later) ought to be applied when adding new sources of microwave radiation such as those from Smart Meters that are active night and day in our homes and places of work.

On page 14 of the CCST report, the statement “There is currently no definitive evidence linking cell phone usage with increased incidence of cancer” is another misleading statement that tends to minimize the cancer risk from cell phones.  If the authors of the CCST report had looked at other papers from the scientific literature (not mentioned in pages 38-44 of the CCST report), they might come to different conclusions.

There is mounting evidence of various types of tumors being caused from cell phone usage including parotid gland tumor (Czerninski, 2011), meningioma (Hardell et al., 2006), acoustic neuroma (Sato et al. 2011), brain tumors (Hardell&Carlberg, 2009) and testicular tumors (Hardell et al., 2007), to name only some.Considering the increasing number ofscientific papers describing various types of tumors associated with non-thermal radiation from cell phones that are appearing in the medical literature, it is not helpful that non-thermal radiations from Smart Meters, which might potentially add to our long-term susceptibility to serious diseases, be minimized as was done in the report.

2. The minimization of the need for lower exposure standards

The report states on page 8 that “…given the existing uncertainty about non-thermal effects, there is no generally accepted, definitive, evidence-based indication that additional standards are needed.” This statement is misleading since an international collaboration of researchers in this field have called for a reexamination of the current ANSI standard based on the increasing evidence of the adverse effects of low-level electromagnetic fields (Hardell and Sage, 2008)  Variousresearch groups have consistently warned that the existing guidelines may be inadequate (Hyland, 2000; Levitt &Lai 2010;Bioinitiative Report, 2007).

Even the International Commission on Non-Ionizing Radiation Protection (ICNIRP) stated in 1998 that “interpretation of several observed biological effects of electromagnetic fields is further complicated by the apparent existence of “windows” of response in both the power density and frequency domains.  There are no accepted models that adequately explain these phenomena, which challenge the traditional concept of a monotonic relationship between the field intensity and the severity of the resulting biological effects.” (ICNIRP, 1998).  In other words, there are windows of sensitive biological response in which potential health effects can occur at much lower exposure levels than currently mandated by the FCC standards.

Already in 1999, the federal government’sRadiofrequency Interagency Work Group (RFIAWG) had “identified certain issues thatwe believe need to be addressed to provide a strong and credible rationale to support RF exposure guidelines.”  Dr. Gregory Lotz from the Department of Health and Human Services, National Institute for Occupational Safety and Health addressed these specific issues in a letter dated June 17, 1999 to Mr. Richard Tell, then Chair of the IEE SCC28 (SC4) Risk Assessment Work Group.  Ironically, it was this same Richard Tell Associates of Las Vegas, NV who wrote the report for PG&E describing the apparent safe exposure limits of the Smart Meter program that was also referenced in the CCST report (Tell, 2005; Tell, 2008).

The Tell Associates report simplified the apparent safety of the Smart Meter radiation by: 1. Only considering a single isolated Smart Meter radiator in free space; 2.Time averaging the pulse RF radiation so that it appeared as a low level of 8.8 uW/cm2; 3. Not considering other RF microwave emitters in the home environment; and 4. Considering only ground wave reflections of the microwave emissions and no other reflective surfaces (see below).  The report also does not address the concerns of the federal RF Interagency Work Group including among other concerns: 1.The biological basis for local SAR limit; 2. the selection of an adverse effect level; 3. the nature of acute versus chronic exposure; 4. the intensity or pulsed or frequency modulated RF exposure; and 5. the issue of time averaging.  These are critical issues which makes the issue of proper exposure guidelines a central issue in this matter.  It further casts great doubt on the conclusions of the CCST report that downplays the need for new, lower exposure standards.

Epidemiologic evidence is a major contributor to the understanding of the potential effects of EMF on health. The International Agency for Research on Cancer (IARC) classified EMF as a “possible human carcinogen”, or a Group 2B carcinogen; (IARC, 2002) this classification was mostly based on consistent epidemiological evidence.Although the body of evidence is always considered as a whole, based on the weight of evidence approach and incorporating different lines of scientific enquiry, epidemiologic evidence, as most relevant, is given the greatest weight.

Several European countries, having taken a deeper look at recent scientific data, are beginning to follow a different approach to the RFR question.  They recommend prudent avoidance in siting cell tower antenna installations near schools, hospitals or wherever people congregate.  This approach is part of what is called the Precautionary Principle, which has been adopted in many countries, including the U.S., for various applications in international treaties.  The Precautionary Principle holds that when questions of safety are concerned, precautions should be taken to protect public health even if scientific data is incomplete, or the mechanisms of action are not understood (Levitt, 2000; Kheifets et al., 2001).

3. The increase in radiation levels at potential local hotspots through reflection

Although it is true that the Smart Meters comply with current U.S. Federal Communications Commission (FCC) guidelines because they operate below the existing power density thresholds, power density is not the only factor determining biological effects from radiofrequency radiation.  The power density level safety standards are solely based on thermal considerations, yet it is the non-thermal radiation levels that are the key to potential health impacts. The non-thermal effects occur at lower levels from various emitting radiators now in common use including cell phones, cordless phones, Wi-Fi, Wi-Max, to name only some.  Smart Meters add to this cumulative ubiquitous low-level background microwave environment.

RFR can increase to higher levels than anticipated due to surface and ground reflections from the various radiators. (Hondou, 2002; Hondou et al,2006;Vermeeren et al, 2010), even at some distance from the sources.  These scientific studies suggest that reflectivity from other metallic surfaces and reflective materials could increase the power density of the RF fields significantly, leading to the development of hot spots in our homes.  Richard Tell Associates report commissioned by PG&E in 2005, and updated in 2008, contained calculations of the intensity of RF fields produced by the Smart Meters that included only ground reflections estimated to increase the field strength by 1.6 times (equivalent to a 2.56-fold increase in the power density).   In light of recent scientific findings and actual computer modeling studies, the Tell estimate of ground reflectivity may be significantly too low and does not address the development of possible hotspots in the home.  If microwave hotspots occurred near sleeping quarters or near a baby’s crib, their health impact could be highly significant.  Sage Associates report, which made some estimates of Smart Meter impacts through computer modeling, even suggests that under certain assumptions the emissions from Smart Meters and their local reflections might even exceed FCC standards (Sage, 2011).

The CCST report never even acknowledged the need for computer modeling to ascertain the potential riskof higher microwave radiation levels in our homes as a result of Smart Meter installation, alone or in interaction with other microwave emitters.  We believe that such modeling is vital if the public is to know the potential for the developmentof hot spots in sensitive living areas.  The Richard Tell Associates study carried out for PG&E did not consider other microwave sources in the environment stating, “The study does not take into account the potential for RF fields that may be produced by other devices or systems that are not part of the Smart Meter program upgrade.  Such devices or systems include cellular telephones, cellular telephone base stations, broadcast radio and TV stations, microwave ovens used in the home or any other source of RF energy.”

4. The lack of information about the impact of pulsed radiation from Smart Meters

The is considerable difference between the biological impact of pulsed microwaves, as produced by Smart Meters, compared to continuous waves, such as those produced by microwave ovens.  No distinction is made in the safety criteria between continuous and pulsed waves because of the narrow-minded focus on thermal damage alone.

Many scientific studies have pointed out that radiofrequency radiation with different modulations and pulse characteristics produce different biological effects even though they may produce the same pattern of different specific absorption rate distribution and tissue heating (Levitt &Lai, 2010).

Peer-reviewed studies have shown that the differences in modulation patterns and waveforms can produce quite different biological effects.  They include the works of Arber and Lin (1985); Campisi et al (2010); Huber et al. (2002); Luukkonen et al. (2009); d’Ambrosio et al (2002), among many others.  Already Soviet research in the 1960s showed that pulsed waves induced stronger and often inhibitory biological and neurological effects than continuous waves (Osipov, 1965).  A review of the hazards to U.Smilitary personnel from high frequency electromagnetic radiation was provided by Pollack (1967) which gives an overview of the extensive Eastern European research in this field.

Marha (1963) described allowable intensities for frequencies above 300 MHz in Czechoslovakia for continuous waves as 25 uW/cm2 but limited pulsed waves to only 10 uW/cm2.   Note that these Czech recommended levels were considerably lower than the approximately 600 uW/cm2 allowed for the RFR from Smart Meters operating in the low 900 MHz band mandated by the FCC based on only thermal consideration.  Also not well known in the West is the Soviet work showing the adverse effect of non-thermal pulsed microwave radiation on cardiac rhythms in animals (Presman&Levitina, 1962).

The CCST report is misleading because it compares the Smart Meter emissions to those of microwave ovens.  Microwave ovens produce much higher power output but are not modulated or pulsed in any way.  It is imperative to understand that it is the modulation or pulsation pattern that leads to biological effects at non-thermal power levels.  Biologically-sensitive amplitude windows have been found at specific frequencies that lead to the selective release of calcium from cell membranes.  However, above and below these unique power densities there is no observable effect.  Pulses and square waves have the greatest biological impact because they produce rapid changes in voltage across biological membranes.  Un-modulated carrier waves have little or no biological effect except if their power is sufficient high, such as in microwave ovens.  Comparing the power levels between modulated and un-modulated devices, as the CCST report does, is thus misleading.

The potential health effects from chronic exposure to pulsed, low power density level electromagnetic fields might take several years to appear.  These types of radiations produced by Smart Meters are of concern for their potential health impacts onthe electrically hypersensitive part of the population.  In Sweden, electrohypersensitivity(EHS) is an officially recognized functional impairment; however it is not regarded as a disease (Johansson, 2006).  Electrical hypersensitivity has been reported by many authors from various industrialized countries over the last 20 years.  The CCST report does not consider this segment of our population at all.  Yet in the United Kingdom there are excellent resources about this condition, especially the work of Bevington (2010) containing over 700 references.

The ICNIRP, IEEE and ANSI standards that are currently in effect consider only thermal effects of microwave radiation where the energy absorption is fairly linear and thus the protective guidelines are logical.  However these energy absorption guidelines would not be appropriate when frequency-specific amplitude windows are involved leading to adverse biologicaleffects that can depend onmodulation patterns, pulse repetition rates, duty cycles, and other frequency spectrum characteristics.  With the current PG&E-mandated Smart Meter program having a 20-year life expectancy, Californians will be living with potential health impacts from this unproven technology in our homes for the next two decades.

5. The lack of information on the health impacts of night-time radiation from Smart Meters

Another problem that was not addressed in the CCST report is potential health effect of microwave radiation exposure during our sleep which may adversely affect our biological and circadian rhythms (daily physiological regulatory cycles). Smart Meters will pulse intermittently day and night and may have an adverse effect on sleep cycles.  We do not use our cellphones during sleep, yet Smart Meters will continue to emit pulsed RFR all night long.

Exposure to microwave/radiofrequency fields affect the neuroendocrine system causing neuroendocrine chemical modulations and behavioral reactions.  Already in 1970s it was known that resonant absorption within the cranium may result in the focusing of energy and the production of electromagnetic “hot spots” in the brain (Johnson & Guy, 1972).  Microwaves may disturb the critical hormonal regulatory areas including the hypothalamic-pituitary axis through “low intensity” exposure.  The body may elicit “different responses relative to the timing of the exposure with respect to circadian rhythm” (Michaelson,1982).  At night, while sleeping, the body is principally in a repair mode and the exposure to microwave radiation from Smart Meters may potentially be more damaging than exposure during the day.  It is vital that long-term exposure studiesduring the night be carried out to determine if Smart Meter pulsed microwave radiation could have an adverse biological effecton our population.

The European Commission’sScientific Committee on Emerging and Newly Identified Health Risks report on “Health Effects of Exposure to EMF” stated that “No health effect has been consistently demonstrated at exposure levelsbelow the ICNIRP-limits established in 1998. However, the data base for this evaluationis limited especially for long-term low-level exposure” (SCENIHR, 2009).  In other words, we just don’t know what will be the long-term effect of consistent low level exposure of RFR such as those imposed by Smart Meters in addition to the other microwave radiation sources now increasingly being used in our homes.

6. The lack of modeling or actual measurements of the contribution from Smart Meters to the existing background microwave radiation

The CCST report is misleading on page 20 where it says that he exposure levels to people living in metropolitan areas is quite low, around 0.005 uW/cm2.   They base their assertions on an outdated report fromJuly 1986 made by the U.S. Environmental Protection Agency entitled The Radiofrequency Radiation Environment: Environmental Exposure Levels and RF Radiation Emitting Sources, EPA 520/1-85-014.  This data is totally outdated since it reflects the situation before the modern cellular telephone networks were put in place.

Already in 2000, in Sweden, the radiofrequency and microwave radiation levels in urban areas were approximately ten times higher than they were in the 1980s—and most of the increase is due to wireless communications, according to Dr. YngveHamnerius of Chalmers University of Technology in Göteborg, Sweden. Hamnerius measured radiation levels in the 30 MHz-2 GHz frequency range at 26 sites across Sweden with varying levels ofurbanization. In cities, the median power density was 0.05 uW/cm2, with a 61% average contribution from GSM cell tower base stations. (Microwave News, July/August 2000).  In the U.S. we do not have any up-to-date data since the U.S. Environmental protection Agency has not carried out any research studies for two decades.  I have personally measured background microwave radiation levels that are hundreds of times higher in many metropolitan areas than the values described in the CCST report using 1986 EPA data.

This increasing amount of background microwave radiation has become of  medical concern in many parts of the world.  For example in March 23, 2009 European scientists called for a reassessment of the damaging health impacts of increasing levels of electromagnetic radiation (Electrosensibilité : Appel des scientifiques du 23-03-2009).  Similarly, in November 2009 a meeting of international experts on the biological effects of electromagnetic fields met in Stavanger, Norway to discuss the unprecedented global exposures to artificial electromagnetic fields from communication and power technologies.  Many scientists at this meeting recommended that lower limits be established for electromagnetic fields and wireless exposures due to the health impacts at much lower exposure levels than are now considered safe.

The United States government essentially stopped all research on RF radiation effects on the environment, including population exposure, in 1996.  The Environmental Protection Agency’s budget and staffing for RF radiation activities was $821,000 from 1990 to1995 and only $25,000 between the years 1996 to 2000 (Levitt, 2000, page 271).  Essentially, there was no government money spent in the last 15 years by the EPA to fund a reexamination of the RF exposure limits by the National Council on Radiation Protection and Measurement (NCRP).  Our changing microwave environment is thus not being studied by our federal government.  If the federal government is not looking after our health concerns concerning low level electromagnetic fields, it is imperative that utilities have their new microwave technologies evaluated by state government research laboratories or public health organizations prior to letting this technology be deployed on a largely unaware California public.

What is needed is an up-to-date series of measurements in dense urban environment that measures the combined RFR levels from all radiating emitters and estimates or measures the cumulative effect of Smart Meters and collectors to radiation exposure levels in homes.  This must include all RFR emitters that are connected to the MESH and home area networks (HAN) as deployed by PG&E.  Only independent assessments or measurements of these radiation levels ought to be considered, not those conducted by companies that have direct or indirect connection to the utilities.  Until these studies are available, it is recommended that the Precautionary Principle be adopted.

7. The lack of health and environmental consideration by the CPUC when the Advanced Metering Infrastructure (AMI) was approved.

On July 20, 2006, the California Public Utilities Commission (CPUC) issued their final opinion, Decision 06-07-027, authorizing Pacific Gas and Electric to deploy an Advanced Metering Infrastructure (AMI) that would lead to the automation of 5.1 million electric meters and 4.2 million gas meters.  The CPUC decision was in response to PG&E’s application 05-06-028 filed on July 16, 2005.    In Section 7 (Technology) of this CPUC decision, the AMI deployment was described as using Power Line Carrier technology for electric meters and a fixed network system with radio frequency communications channels owned by PG&E for gas meters.  The system was to have a useful life of 20 years.  In section 15 (Environmental Review) of the Decision, it stated that there is no need for an analysis of PG&E’s AMI deployment pursuant to the requirements of the California Environmental Quality Act (CEQA).  It appeared that due to the suggested Power Line Carrier technology to be employed, the health or environmental effects were not considered at the time and the CPUC felt under no legal obligation to undertake any environmental review before approving the PG&E application.

On March 12, 2009, the CPUC made another Decision 09-03-026 in response to PG&E’s application A.07-12-009 filed on December 12, 2007 to expand the AMI program significantly.   Now the CPUC approved the establishment of microwave mesh networks as well as incorporating a Home Area Network (HAN) gateway deviceinto advanced electric meters to support in-home HANapplications; and upgrading PG&E’s electric meters to solid state meters,now called Smart Meters.  In this decision, which conveniently expanded its 2006 AMI deployment decision, there was absolutely no mention of any environmental or health impact even though a whole new radiofrequency technology infrastructure was now approved for deployment on every home and business in California.  We believe that this decision represents a gross degree of negligence by the CPUC in protecting the health and safety of the citizens of California.  The CPUC needs to readdress the health and safety issues directly and immediately halt the installation of the Smart Meter program pending clarification of the issues raised by many scientific investigators who have commented on the inadequacy of the CCST report.


Conclusions

The time needed for a new technology to be developed and rolled out is much shorter than the time needed for research to investigate the possible health effects on the general population.  The current Advanced Metering Infrastructure using microwaves in the 900 MHz frequency spectrum approved by the CPUC is going to adversely impact the physiology and ultimately the health of many Californians over the next twenty years, the anticipated life time of the Smart Meters now being deployed.  This program is being implemented without widespread public knowledge or approval and without the specific informed consent in writing from every household.

Already the most sensitive members of our society, those who are especially vulnerable by being electrically hypersensitive, are registering health complaints such as headaches, sleep disturbances, cognitive difficulties, dizziness, heart palpitations, to name only a few.  Most of these symptoms could also be related to other medical conditions making it difficult to ascribe their appearance specifically to the Smart Meters radiation directly. Although not yet recognized in this country as a state of physiological imbalance, hypersensitivity of human subjects to exposure to electric and magnetic fields has been reported for over 20 years by many authors in many industrialized countries.  If only 1% of California’s population were to report symptoms of electrical hypersensitivity after Smart Meter installation, over 370,000 people might be adversely affected by RFR.

The dissemination of this Smart Meter technology could have been accomplished without using radiofrequency radiation by using much safer power line, fiber optic or telephone communications technology.  For example, a Smart Meter power line communications technology was used by Italian utilities in 27 million households using meters designed in California.  In the Netherlands, the population concerned about the security and health issues of Smart Meters was given the options to opt out from having the meters installed.  Californians were never given this option. Yet this AMI program, costing utility customers over $2 billion, represents the largest technology roll-out in the history of Pacific Gas and Electric.  Ironically, it is being financed by the rate payers without their direct consent.

This program represents an epidemiological experiment involving our unsuspecting population whose outcome will only be fully known after many years exposure.  It is being shepherded through the regulatory process by the CPUC who has not seen fit to study the possible adverse health impacts of this technology before approving its usage.  It has never shown any willingness to seriously consider the well-documented non-thermal effects of pulsed microwaves on living systems and will undoubtedly use the misleading CCST report to avoid any questions about future health implications of this technology.   Because of the uncertainties of adverse long-term health impacts, the CCST ought to have recommended that a Precautionary Principle be invoked that would allow more time to directly study the effect of this pulsed radiation with both in vitro and in vivo testing in realistic settings of the mesh network, especially in high density Smart Meter environments in our cities.

Additionally, in cities the Subterranean Network Deployment System (SUNDS) is now also being installed by PG&E.  This will add even higher microwave exposure levels to the general population.  Any description of this new system was conspicuously absent from the CCST report.  At a minimum, the utilities and CCST ought to have carried out extensive computer modeling to assess the impact of Smart Meter technology in realistic settings, taking into account the other wireless technologies have already been deployed and which have significantly increased the background microwave exposure of the population over the last 20 years.

In summary, we find that the CCST report is incomplete and misleading giving California State regulators a false sense of security while potentially endangering the future health and well-being of Californians.  It is requested that the current Smart Meter deployment be halted pending a more comprehensive scientific investigation of the biological response and health impacts of the non-thermal aspects of this technology.  All households should be offered full disclosure about possible exposure levels, modulation patterns, peak power levels and interactions with other parts of the microwave spectrum in their home environments.  Additionally, those who are sensitive to this radiation must be given the choice to opt out from having this form of RFR imposed upon their residential dwellings.

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Janet Newton, President EMR Policy Institute

To:       California Council on Science and Technology

Date:   31 January 2011

RE:      Comment on: Health Impacts of Radio Frequency from Smart Meters

Response to Assembly Members Huffman and Monning (CCST Report)

Cc:      via E-mail to:

California Assemblyman Jared Huffman

California Assemblyman Bill Monning

Thank you for the opportunity to comment on this important public healthy policy issue.

The EMR Policy Institute (EMRPI) is a national advocacy organization established in 2003 whose goal is to create better cooperation between public health regulatory agencies in order to mitigate unnecessary hazardous electromagnetic radiation (EMR) exposures. We educate policy makers and the public on the need for sound, biologically-based human safety policy that protects public health regarding EMR exposures across the electromagnetic spectrum.

EMRPI continues to challenge the inadequacy of the US safety policy on electromagnetic and RF radiation exposures by submitting official comment to key federal agencies. Our record of formal comment as individuals and through our organization dates back to 1997. It includes official comment to key federal agencies such as the NAS, FCC, FDA, GAO, NIOSH, NTIA and DOJ.

The directors of EMRPI have participated in taking three cases to the US Supreme Court challenging the FCC’s RF safety policy as inadequate to protect all members of the public. In each case the Court denied certiorari on procedural grounds.

This EMRPI Comment is based upon our 14-year record of scrutiny of the inadequacies in the current FCC radiofrequency radiation policy that was put in place in 1997. Since 1997 the FCC has resisted all calls to address these inadequacies, i.e., to develop biologically-based safety limits for human exposure to RF radiation that protect all members of the public.

Currently there are three U.S. federal mandates promoting wireless technologies that can adversely affect the health and well being of all Americans, and especially those who require Implanted Medical Devices (IMDs) as well as those who suffer from the functional impairments of EHS and Radiofrequency Sickness. These population subgroups warrant protection by the under Americans with Disabilities Act provisions. There is no federal agency coordination to enforce these provisions. The mandates are:

• Wireless broadband

• SmartGrid and Smart Meters (wireless utility meters)

• Unlicensed commercial use of TV White Spaces spectrum.

Ubiquitous involuntary exposure to Electromagnetic Interference (EMI) with IMDs from these sources as well as from the plethora of wireless consumer devices now on the market presents the greatest potential for harm for Americans with IMDs. The FCC’s focus on EMI and “safety” continues to protect devices rather than members of the public as found in its 2009 announcement of its International TV White Spaces Fellowship and Training Initiative:

. . . by building on a proven concept: the safe deployment of new, intelligent devices in the unused spectrum that exists between television channels without causing undue interference to adjacent users. (Emphasis added.)

“Adjacent users” refers to commercial communications devices rather than to humans with IMDs.

In view of California’s initiative to deploy wireless smart meters statewide EMRPI submits the following comment on the CCST Report:

1.  The January 2011 CCST Report misses out on a key opportunity to address its own “Key Report Findings” and “Other Considerations” by failing to provide the public with a clear analysis of the scientific record upon which the current FCC RF radiation safety policy is based. On p. 8 The CCST Report specifically references the 2008 National Academies of Science Report: Identification of Research Needs Relating to Adverse Health Effects of Wireless Communication (NAS Report at: www.nap.edu/catalog.php?record_id=12036) The National Academies of Science performs provides a parallel service for the US federal government that the CCST does for the State of California, yet the CCST Report fails to include the specific details of the 2008 NAS Report findings.

2. Safety regulations are based on the published record of scientific studies in a given field. The NAS Report enumerates the holes in the RF research record upon which FCC RF safety policy is based. In failing to include the NAS Report findings, the CCST Report missed the mark for explaining its own Key Finding #3 – To date, scientific findings have not identified nor confirmed negative health effects from potential non-thermal impacts of RF emissions such as those produced by existing common household electronic devices and smart meters. . . and Other Considerations #3 – Consumers should be provided with clearly understood information about the radiofrequency emissions of all devices that emit RF including smart meters.

3.  On p. 7 CCST Report states that: Given current scientific knowledge, the FCC guideline provides a more than adequate margin of safety against the known thermal effects. It fails, however, to specify the holes in the “current scientific knowledge” delineated in the NAS Report.

4.  On p. 8 CCST Report states that:: At this time there is no clear evidence that additional standards are needed to protect the public from smart meters or other common household electronic devices. However, the 2008 NAS Report documents the need to characterize specific aspects of real-life public exposure to RF radiation that are not addressed in the scientific record upon which the current FCC RF safety policy is based (see pp. 13-44):

a.  Exposure of juveniles, children, pregnant women, and fetuses both for personal wireless devices (e.g., cell phones, wireless personal computers [PCs} and for RF fields from base station antennas.

b.  Variability of exposures to the actual use of the device, the environment in which it is used, and exposures from other sources.

c.   Multilateral exposures.

d.  Multiple frequency exposures.

e.  Location of use (both geographic location and whether a device is primarily used indoors or outdoors).

f.    Models for men and women of various heights and for children of various ages.

g.  Exposure to rooftop maintenance workers and to members of the public that live in close proximity to multiple co-located base station antennas.

h.  Exposure to subpopulations among maintenance employees.

i.    Chronic exposures that are similar to those from existing TV and radio antennas.

j.    Multilateral exposure to the typical arrangement of four to six antennas with multiple frequencies, rather than a single antenna radiating at a single frequency from a single direction as used in laboratory studies.

k.   Exposure to others sources of RF radiation such as cordless phones, wireless computer communications, and other communications systems.

l.    Exposure to the hand or the human lap or parts of the body close to the device.

m. RF exposure in close proximity to metallic adornments and implanted medical devices (IMDs) including metal rim glasses, earrings, and various prostheses (e.g., hearing aids, cochlear implants, cardiac pacemakers).

n.  Models for whole-body exposure due to base station antennas.

o.  Sufficiently long exposure and follow-up to allow for detection of effects that occur with a latency of several years.

p.  Lack of information concerning the health effects associated with living in close proximity to base stations.

q.  Research that includes children, the elderly, and people with underlying diseases.

r.    Research on possible adverse RF effects identified by changes in EEG activity.

s.   Lack of information on possible neurophysiologic effects developing during long-term exposure to RF fields.

t.    Studies focusing on possible adverse RF effects identified by changes in cognitive performance functions.

u.  Effects of RF exposure to the sensitive biological targets of neural networks. v.   Possible effects of RF exposure on fetal and neonatal development.

w.  Possible influences of exposure on the structure and function of the immune system, including prenatal, neonatal, and juvenile exposures.

x.   Possible influences of RF exposures on the structure and function of the central nervous system, including prenatal, neonatal, and juvenile exposures.

5.  At p. 8 CCST Report states that: No clear causal relationship between RF emissions and non-thermal human health impacts has been scientifically established, nor have the mechanisms that might lead to such biological impacts been clearly identified. In this statement CCST Report leaves the inaccurate impression that science has established the “mechanism” or cause of development of other diseases such as cancer, Alzheimers’ Disease or ALS, which is not the case. Lack of a single mechanism for causation of adverse health effects arising from exposure to non- thermal levels of RF emissions is not a valid rationale to negate the scientific evidence demonstrating these non-thermal effects.

6.  Illustrating inadequate protection under the current FCC RF safety policy is the experience of geophysics professor Gary Olhoeft PhD with the critical EMI problems he encounters daily with his Medtronics Deep Brain Stimulator (DBS). Prof. Olhoeft’s comment was read at the first Public Comment period at the July 26-27, 2010 FCC- FDA combined public meeting on, “Enabling the Convergence of Communications and Medical Systems.” Despite Dr. Olhoeft’s insightful analysis and account of this one example of EMI between wireless systems and his DBS, neither the FCC moderator nor the FDA moderator of the following day’s panel on Electromagnetic Compatibility (EMC) raised one question on this EMI topic so critical to the life, health and well being of millions of Americans. Even the last panel discussion, Electromagnetic Compatibility – How to Promote EMC, made no mention of compatibility with implanted electronic medical devices such as Deep Brain Stimulators that treat Parkinson’s patients, or insulin pumps for diabetics, for example.

Professor Olhoeft submitted his written Comment in the current US Department of Justice Advanced Notice of Proposed Rule Making proceeding. See also the video of his presentation at the 2009 EMRPI scientific conference, “Electromagnetic Radiation Impacts on Human Health,” at: www.youtube.com/watch?v=jo-B6LWfVzw&feature=related

7.  No federal agency is keeping track of cumulative wireless power density, nor identifying critical levels and locations where individuals who require IMDs may be at risk.

8.  The FCC continues to issue compliance statements for new wireless devices and systems without regard for existing RF levels. Those most seriously threatened are the NIH-estimated 20 million Americans who require IMDs. These 20 million Americans account for 8-10% of the US population. The most serious threat to them is from Smart Meters and wireless broadband because of their ubiquitous deployment throughout the public’s living and working environments and now throughout medical treatment settings.

9.  In stark contrast to the lack of public health concern in key US federal and state agencies are these precautionary provisions called for in The European Parliament April 2009 Resolution approved by a vote of 559-22: www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//TEXT+TA+P6-TA-2009-0216+0+DOC+XML+V0//EN

•     Particular consideration of biological effects, especially given that some studies have found the most harmful effects at lowest levels;

•     Evaluation of potential long-term adverse effects of mobile telephony radio frequencies;

•     Increased investigation of harmful effects of multiple exposures to different EMF sources, particularly for children;

•     Member States to follow the example of Sweden and to recognize persons that suffer from electrohypersensitivity as being disabled so as to grant them adequate protection as well as equal opportunities;

10. Because individuals with electronic IMDs and EMR functional impairments are

inherently sensitive to RF and EMR exposures, EMRPI strongly urges the State of California to broaden #4 of CCST Other Considerations to require Smart Grid / Smart Meter options that employ fiber optic and hard-wired data transmission rather than wireless transmitting Smart Meters.

Respectfully submitted by

The EMR Policy Institute

Janet Newton, President

P.O. Box 117

Marshfield VT 05658

contact information available only in attached download

www.emrpolicy.org

RAYMOND RICHARD NEUTRA M.D. Dr. PH

RAYMOND RICHARD NEUTRA M.D. Dr. PH

956 EVELYN AVENUE

ALBANY CALIFORNIA

94706

contact information available only in attached download

January 30,2011

CCST

Dear Sirs,

Some citizens are worried about the involuntary application of wireless real time monitoring of their electricity use. Their concerns relate to the invasion of privacy and the addition of radio frequency (RF) electromagnetic and electric and magnetic exposures from meters in their own homes and in their neighborhoods. Some have pointed out that there are other technologies now in use in other countries that avoid the exposures.

Public officials approached you with a very narrow framing of the issue asking you:

(a) if one could guarantee an absence of health effects if RF exposures were always below current thermally based standards.

(b) If other standards were needed to deal with non-thermal health effects

You answered:

1.   The FCC standard provides a currently accepted factor of safety against known thermally induced health impacts of smart meters and other electronic devices in the same range of  RF emissions. Exposure levels from smart meters are well below the thresholds for such effects.

2.   There is no evidence that additional standards are needed to protect the public from smart meters.

Your first answer doesn’t respond to the official’s first question at all, instead it states what all parties agree to, the standard protects against thermal effects and smart meters emit fields that are below the standard.

Your second answer is technically a falsehood. There is lots of evidence that would suggest that RF and ELF exposures well below the current standards may be capable of causing added lifetime risk that exceed the benchmark which triggers health based regulations ( 1 per hundred thousand).  You could have turned your second answer into a true statement by saying something like this:

“When our panel, that included no epidemiologists, reviewed the extensive literature, epidemiological and non epidemiological on non-thermal RF exposures, we concluded that it is not beyond a reasonable doubt that non-thermal exposures are capable of adding life-time risks of regulatory concern. This is because we would require a clear understanding of the physical induction mechanism , the carcinogenic mechanism and toxicological and epidemiological effects well above the resolution power of the studies before we would say that non-thermal exposures can cause significant risk at the ‘beyond a reasonable doubt level’.”

A beyond a reasonable doubt standard is required in criminal proceedings and would be inappropriate in a civil proceeding, where only a “more likely than not” standard is required. We were all reminded of this in the famous OJ Simpson trials.

So, what certainty standard is applicable here? How certain to we have to be of how much risk before we move from the status quo to cheap and expensive measures to reduce smart phone exposures? On page 24 you say “.. retrofitting millions of smart meters with hard wired technology could be difficult and costly. Perhaps more importantly, retrofitting smart meters would not address the significantly greater challenge presented by the billions of mobile phones in use globally.”

This sentence also includes important unstated assumptions:

a)  If other actors are exposing you to harm more intensely than I, then I have no moral duty to remove my less intense harm until he removes his.

b)  It would not be cost beneficial to switch to wired smart meters

c)  It would raise utility rates substantially to switch to wired smart meters.

d)    I have no moral duty to switch to a lower exposure meter, even if the impact on utility bills are minimal.

I provided your staff with a link to the many projects of the California EMF Program at www.ehib.org/emf. In it they would have found our analysis of policy issues with regard to power lines and house wiring and our extensive risk evaluation. In it we assessed the available options and their costs. You made no attempt to do this even in a rough way. Then we examined what the adoption of these options would do to utility rates. You did not do that either. Then we asked how certain we would have to be of how much added lifetime risk of disease before it would be cost beneficial to move to the cheap and expensive options. A certainty well below the “more likely than not” standard would have sufficed to justify cheap options to even a hard hearted utilitarian. We also explicitly carried out a duty ethics analysis of the situation which you did not do. In our risk evaluation we tried to avoid the pitfalls of misleading language, such as using the phrase “no evidence” to stand for “ the evidence doesn’t convince us.” As you know this phrase is much beloved by those who deny human influences on global climate change. Then we avoided expressing exposures as fractions of irrelevant standards as you have done. We avoided expressing our scientific certainty as a dichotomy between “beyond a reasonable doubt” and “not beyond a reasonable doubt” as you effectively have done. This dichotomous formulation has also been avoided in reports on the human effects in Global Climate Change. Finally we made explicit the rules for weighting various streams of scientific evidence to develop our degree of certainty. You provided neither your factual grounds nor rules of inference for justifying your “no evidence” statement. Expressing smart phone exposures as a fraction of the thermal standard makes it sound small, expressing it as a multiple of the background would make it sound alarming. Your graph was enough.

I said at the beginning that the public officials framed their question in a narrow way and a way that was overly focused on numerical standards as a solution to environmental and occupational hazards. We don’t control automobile trauma with a standard, we control it with a technical solution, seat belts, airbags and traffic rules. We don’t control the carcinogenic risk from wood dust by a wood dust standard, we mandate dust masks and air vents. I personally don’t think we know enough about the exposure metric to set a standard at this time.

The solution to any risks of regulatory concern from PG &E’s smart meters could be to switch to wired smart meters now and gradually replace the wireless ones if the rate payers can live with the impact to their utility bills.

If the public officials narrowed their questions with the intent of  receiving an answer that would take this issue off their radar screen, than you have responded in a narrow way that would serve such a purpose.

This is not the way I would like to see public policy pursued. Unfortunately you are not alone in this pattern of language use, hidden assumptions and making the uncertain seem certain so a to provide cover for policy.

Sincerely yours

Raymond Richard Neutra MD.  DrPH

Cindy Sage, MA

Sage Associates
Environmental Consultants

January 17, 2011

Susan Hackwood, PhD
Executive Director
California Council on Science and Technology

Lora Lee Martin, Director
Strategic Policy Initiatives and Government Affairs
California Council on Science and Technology

Subject:            Letter of Comment on Smart Meter Report

This letter addresses the CCST Smart Meter Report issued on January 11, 2011.  Overall, the report does begin to highlight international scientific concerns about chronic, low- intensity radiofrequency radiation exposures.  Radiofrequency radiation health risks have been and continue to be addressed by scientific bodies around the world as a credible threat to health. [1-4]

The Report text provides an introduction to the science and public health questions on health impacts that can reasonably be expected from chronic exposure to low levels of RF in close proximity to occupied space in homes, schools and other daily living environments.

Conclusions Are Not Supported by Evidence of Compliance with FCC Safety Limits

There is no solid basis in the CCST report to conclude (or to support the contention) that

FCC public safety limits are met for smart meters, in the manner installed and operated.

Conclusions Disregard Evidence in the Report for Possible Health Risk

The text of the report only partially documents potential health risks from low-level, chronic exposure to radiofrequency radiation. The conclusions ignore this discussion.

Conclusions Do Not Follow from Report

Conclusions of the report are inconsistent with the report’s more balanced warnings about possible risks to health. The overall legitimacy of the report is cast into doubt as a result.

CCST’s report could equally well have concluded ‘there is ample evidence to advise the California Legislature that, based on multiple studies of radiofrequency radiation below current FCC safety limits, it is advisable to issue a cautionary warning on the wireless component of smart meters until a full assessment of their effects is completed by independent experts. Further, it can be concluded that the continued rollout of wireless smart meters may increase public health risks on a widespread basis and should be reconsidered in light of the existing scientific evidence and public health warnings for such chronic exposures to pulsed RF.’

I was one of the expert reviewers invited by CCST to submit comments for the Committee.  CCST asked several experts to answer two questions (see below).  Since the Report conclusions apparently ignored much of the expert and committee input – only intervention by the final editor(s) to disregard key evidence explains how CCST’s final conclusions could give rise to the “all clear” message.

Questions asked of Invited Expert Reviewers

1) Are the current FCC standards for smart meters sufficiently protective of public health, taking into account current exposure levels to radiofrequency (RF) and electromagnetic fields?

2) Are additional technology-­specific standards needed for smart meters and other devices that are commonly found in and around homes, to ensure adequate protection from adverse health effects?

CCST Report Conclusions

1) “The FCC standard provides a currently accepted factor of safety against known thermally induced health impacts of smart meters and other electronic devices in the same range as RF emissions. Exposure levels from smart meters are well below the thresholds for such effects.”

This conclusion presents a partial response to Question 1 – only that the FCCs thermal standards are adequate (these standards prevent only heating and burning of tissues, and shock hazard, however). The conclusion does not address non- thermal (or low-intensity) RF exposures, which is really the point.  It also is silent on FCC violations of public safety limits, which have been calculated to occur.[13]

2) “There is no evidence that additional standards are needed to protect the public from smart meters.”

By ignoring evidence for low-intensity RF adverse health effects, the Report essentially then dismissed the need for changes in public safety standards for pulsed RF.  This conclusion simply cannot be reconciled with the evidence presented in the report (thin as it is), nor with the larger body of evidence known to experts in this field. That evidence is now widely discussed by international health and safety experts who find the existing thermal standards inadequate to protect public health. [1,2]

FCC Violations and Excessively High RF Exposures are Ignored

Another report issued on January 1, 201is titled Assessment of Radiofrequency Microwave Radiation Emissions from Smart Meters by Sage Associates.[13]   It documents what RF levels may be expected.  The Assessment seems not to have been considered either by the CCST experts nor the Committee.

The Assessment identified where and under what conditions smart meters can cause FCC violations of public safety limits as the meters are typically installed and operated. The CCST report concludes that all smart meter RF exposures will be well below the FCC safety limits, and this is erroneous.

To date, there have been no other studies that provide sufficient information to support the claim that smart meters comply with FCC regulations. In fact, there is solid evidence from a review of the FCC Grants of Authorization and attached FCC RF exposure studies that many thousands (perhaps millions) of meters are in clear violation of one or more of the explicit limitations noted on each FCC Grant of Authorization. The FCC Grants of Authorization are void unless meters are installed in compliance with every one of those limitations.

The Assessment also shows many cases where, although the FCC safety limits may not be violated, excessively high RF levels from smart meters would be predicted to occur within the home or in other occupied space. In many instances, predicted RF levels are many times higher than those reported to cause adverse health effects. [5-12]

Such exposures, if chronic, would reasonably be expected to result in increased disease and disability.

Misleading Comparisons Are Made to Cell Phones

CCST’s report makes misleading comparisons of RF exposures from cell phone use and from smart meters, an apparent effort to minimize public health concern. If the FCC had thought smart meters would be held to the head in normal operation, they would have required smart meters to be tested for SAR compliance, not power density. These are not the same, and to compare them is wrong.

Cell phones produce a high, localized RF exposure at the head. They are presumed to be used within 20 centimeters (8”) of the body.  Smart meters, like cell towers, create whole- body exposure rather than localized exposure in most circumstances, and specific FCC compliance depends on keeping a 20 cm or greater distance from the meter. Cell phone use is voluntary; smart meter exposure is involuntary. Cell phone use is sporadic or intermittent, but smart meter exposure estimates are ‘all over the map’. There is great uncertainty on this point, and as such, the outcome cannot be known; therefore, no assertion of safety or compliance can be given.

RF Levels from Smart Meters are Unreconciled and Need Assessment

PG&E’s sole figure for RF exposure was given during CPUC proceedings as 1/6000th of the federal health (sic) limit. Nothing is given about the specific conditions under which this estimate might be true (antenna make and model, duty cycle, which FCC formula, what reflection factor, one meter or multiples, etc). However, from that single data point, we calculate that RF exposure to be 0.11 uW/cm2 at 10 feet (where the FCC safety limit is known to be 655 uW/cm2 at the frequencies 915 MHz and 2405 MHz). This means that at 10 feet from the meter, PG&E says the RF level will be 0.11 uW/cm2.

Kundi and Hutter (Pathophysiology, 2009)[2] say they don’t yet find RF health impacts at levels below 0.05 to 0.1 uW/cm2” but do find consistent evidence of adverse health impacts at levels generally above that (based on at least eight cell tower studies conducted internationally). These figures were for healthy adult populations.

From the CCST Report, figures 1 and 7 (identical) give a comparison of RF levels from various sources, including two estimates for smart meters. They are 4 uW/cm^2 at 10 feet, and 40 uW/cm2 at 3 feet away (no source is identified for these estimates, and again, the operational conditions are unspecified).  Another estimate from CCST’s report (pages 17 and 22) says that a ‘worst case’ RF estimate – a meter that transmits continuously – would produce 60% of the FCC limit (which is 655 uW/cm^2 for the combined antenna frequencies), or 393 uW/cm^2. However, the location at which this RF exposure level is calculated to occur is not given.  The information is not useful. But, given the peer- reviewed scientific literature, any of these estimates is too high for chronic exposure to pulsed RF. [1,2]

No one can reconcile or separate reasonable from unreasonable RF predictions without some better, more systematic computer modeling of RF exposures.

Cumulative RF is Not Assessed Prior to Meter Installation

None of the PG&E or the EPRI estimates includes any provision for ‘what amount of RF exists already’ and does the smart meter’s additional RF burden push that location over the FCC limit. The CCST report does not consider cumulative sources of RF (WI-FI, nearby cell tower(s), AM, FM, TV, HAM transmitters, etc). The cumulative RF burden must be considered, including ongoing RF exposures from existing sources.

Further, since these meters are part of a radiofrequency surveillance and communications system that includes cell antennas (to relay RF signals to the utility) and eventually, power transmitters on/within appliances (to relay RF signals within the home to the smart meter), these critical omissions in the overall RF burden placed on people from the ‘smart meter program’ should be assessed. No one can install a smart meter and make a blanket assertion the environment still complies with public safety standards in the after condition, if the before condition is not known.  RF exposures from multiple sources are additive.

Recommendations to CCST

1)  Advise the California Legislature that further assessment of smart meter impacts to public health and safety are necessary before further deployment.

2)  Recommend de-activation of wireless transmitters in meters already installed pending further review.

3)  Recommend that California Legislative hearings be scheduled on smart meters.

4)  Post in their entirety each of the written expert review letters to CCST.

5)  Recommend that the California Department Public Health receive and log smart meter health complaints.

Thank you for the opportunity to comment on the CCST draft report on smart meters. Cindy Sage, MA

Sage Associates

Co-Editor, BioInitiative Report

Research Fellow, Department of Oncology

Orebro University Hospital, Orebro, Sweden

References

1. BioInitiative Working Group, Cindy Sage and David O. Carpenter, Editors.   BioInitiative Report: A Rationale for a Biologically-based Public Exposure Standard for Electromagnetic Fields (ELF and RF) at www.bioinitiative.org, August 31, 2007.

2. Pathophysiology Journal, Special Issue 16: Volumes 1 and 2, 2009.  Elsevier Press.  There are chapters on low- intensity radiofrequency and wireless radiation health effects based on scientific literature from the realms of genotoxicity, genomics and proteomics, neurology, blood-brain barrier effects, stress (heat shock) proteins, immunology and inflammatory diseases, cancer and public health consequences of ignoring warnings given global proliferation of wireless exposures at billions of times greater levels than earth and humans evolved with.

3. WHO Research Agenda, 2010. WHO research agenda for radiofrequency fields, © World Health

Organization 2010

4. REFLEX, 2004.  Risk Evaluation of Potential Environmental Hazards from Low Frequency Electromagnetic

Field Exposure Using Sensitive in vitro Methods.

5. Markova E, Malmgren LOG, Belyaev IY. (2009).  Microwaves from mobile phones inhibit 53PB1 focus formation in human stem cells stronger than in differentiated cells: Possible mechanistic link to cancer risk. Environmental Health Perspectives On-line 22 October 2009 doi:10.1289/ehp.0900781

6. Belyaev IY, Markovà E, Hillert L, Malmgren LO, Persson BR. (2009). Microwaves from UMTS/GSM mobile phones induce long-lasting inhibition of 53BP1/gamma-H2AX DNA repair foci in human lymphocytes. Bioelectromagnetics 30: 129-141

7. Sage C, Carpenter D.O.  (2009). Public Health Implications of Wireless Technologies.  Pathophysiology 16:

233–246.

8. Capri M, Scarcella E, Fumelli C, Bianchi E, Salvioli S, Mesirca P, Agostini C, Antolini A, Schiavoni A, Castellani G, Bersani F, Franceschi C. (2004). In vitro exposure of human lymphocytes to 900 MHz CW and GSM modulated radiofrequency: studies of proliferation, apoptosis and mitochondrial membrane potential. Radiation Research 162: 211-218.

9. Nittby H, Grafstrom G, Eberhardt JL, Malmgren L, Brun A, Persson BRR, Salford LG. (2008). Radiofrequency and Extremely Low-Frequency Electromagnetic Field Effects on the Blood-Brain Barrier. Electromagnetic Biology and Medicine 27:103–126.

ISSN 1536-8378 print/1536-8386 online   DOI: 10.1080/15368370802061995

10. Velizarov S, Raskmark P, Kwee S. (1999). The effects of radiofrequency fields on cell proliferation are non- thermal, Bioelectrochem Bioenerg 1999; 48: 177-180

11. Wolke S, Neibig U, Elsner R, Gollnick F, Meyer R (1996). Calcium homeostasis of isolated heart muscle cells exposed to pulsed high-frequency electromagnetic fields, Bioelectromagnetics 17:144-153

12. Zwamborn APM, Vossen SHJA, van Leersum BJAM, Ouwens MA, Mäkel WN. (2003) Effects of global communication system radio-frequency fields on well-being and cognitive functions of human subjects with and without subjective complaints, TNO-report FEL-03-C148; 148:1-89

13.  Sage Associates, 2011. Assessment of Radiofrequency Microwave Radiation Emissions from

Smart Meters http://sagereports.com/smart-meter-rf/

14.  Grandjean P Bellinger D Bergman A Cordier S Davey-Smith G Eskenazi B Gee D Gray K Hanson M van den Hazel P Heindel JJ Heinzow B Hertz-Picciotto I Hu H Huang T Jensen TK Landrigan PJ McMillen C Murata K Ritz Schoeters G Skakkebaek NE Skerfving S Weihe P.   (2007).The Faroes Statement: Human Health Effects of Developmental Exposure to Chemicals in Our Environment, Nordic Pharmacological Society. Basic & Clinical Pharmacology & Toxicology 102:73–75

Nancy Evans, BS

Comments on

California Council on Science and Technology’s Smart Meter Report, January 2011

Nancy Evans, Health Science Consultant, San Francisco

This report ignores a fundamental public health principle: prevention of harm through a precautionary approach, based on evidence of harm rather than absolute proof of harm. CCST dismissed the substantial body of evidence indicating that non-thermal effects of radiofrequency radiation (RF) are real and include cancer as well as neurological effects.[1]There are no federal standards for RF exposure based on long-term, chronic exposure or on non-thermal effects, precisely thetype of exposure from smart meters and the most likely to causehuman health effects. Even standards for personal wireless devices such as cell phones are based solely on absorbed heat, measured by a unit called the Specific Absorption Rate (SAR).

This report also fails to consider the total exposure to RF, which has increased exponentially because of cell phone antennas and broadcast towers. Wi-Fi networks blanket entire neighborhoods and cities as well as homes, schools, cafes and stadiums. Smart meters add one more layer of involuntary chronic exposure to RF.

It is misleading to compare smart meters to cell phones and other wireless devices that are used voluntarily and that some people choose not to use because of the potential health effects. Mandating wireless smart meters in homes is radiation without representation: an infringement of personal and property rights.

As epidemiologist John Goldsmith wrote in 1995, “There are strong political and economic reasons for wanting there to be no health effect of RF/MW (radiofrequency/microwave) exposure, just as there are strong public health reasons for more accurately portraying the risks. Those of us who intend to speak for public health must be ready for opposition that is nominally but not truly scientific.”[2]

Nancy Evans

contact information available only in attached download


[1]BioInitiative Working Group. Cindy Sage and David O. Carpenter, Eds. (2007). BioInitiative Report: A rationale for a biologically based public exposure standard for Electromagnetic Fields (ELD and RF). www.bioinitiative.org

[2] Goldsmith J (1995). Epidemiologic evidence of radiofrequency radiation (microwave) effects on health in military, broadcasting, and occupational studies. International Journal of Occupational and Environmental Health 1:47-57.

Magda Havas, PhD

Havas Submission to CCST “Report on Smart Meters”.

For those interested, below is my invited submission to CCST as part of a Technical Response Team.

Date: October 12, 2010

From: Magda Havas, BSc, PhD

To:  CCST

Submission on Smart Meters.

Item 1.  Whether FCC standards for Smart Meters are sufficiently protective of public health taking into account current exposure levels to radiofrequency and electromagnetic fields.

In my opinion, the FCC standard for Smart Meters is not sufficient to protect public health. This is based on the following facts:

1.1       Thermal vs. Non-thermal Debate. The thermal vs. non-thermal debate is largely a red herring that has been perpetuated for decades and has influenced the type of research done in the United States. The FCC standard is based on a thermal effect. It was originally based on the amount of radiation that would heat an adult male in the US military exposed to radar. While the heating effect is not disputed, biological effects, some of which have adverse health consequences, occur well below the thermal guideline (Inglis 1970). As a consequence various countries in the world are opting for a “biologically” based guideline rather than a “thermal” guideline, which takes into account not only adult males in peak physical conditions but children, pregnant women, the elderly, and those who have developed electrohypersensitivity (EHS). I will return to the concept of EHS later.

1.2       Guidelines in Russia, Switzerland, Poland, and China are well below the FCC standard (i.e. 10 vs. 1000 microW/cm2 or 1% of FCC guidelines). Some military and government insiders tried to get U.S. guidelines reduced decades ago but were not successful (Pollack and Healer 1967, Dodge 1969). Steneck et al. (1980) provides an excellent account of how the U.S. standards were established for radio frequency radiation.

1.3       Our exposure to radio frequency radiation (RFR) is increasing exponentially as we design more equipment that relies on higher frequencies in the electromagnetic spectrum. Prior to World War II, this type of radiation was negligible. Today we have radar (military, marine, aviation, and weather), we have cell phone antennas, radio and TV broadcast antennas, and a growing number of WiFi hotspots, citywide WiFi and Wi-Max antennas. Inside buildings we have cordless phones, many of which emit microwave radiation even when they are not being used; wireless alarm systems; wireless baby monitors, wireless computers, iPads, and Smart Phones that can connect to wireless internet or WiFi. More children are playing wireless video games than ever before and radio frequency identification devices (RFID) are placed into merchandise to provide information to the manufacturer about consumer habits. The “smart meter” is just another source of exposure that will be placed on every home and in every apartment. Smart meters are being used to monitor use of electricity, gas and water. As part of this system, appliances are being designed to communicate directly with smart meters, all in a wireless mode, which will ultimately increase levels of radiation in the home.

1.4 I work with people who have become electrically hypersensitive (EHS) and I have received emails and phone calls from those who have had smart meters placed on their homes. They complain of ill health and many are unable to use the room closest to the smart meter. These individuals have no place to “hide” from the growing levels of electrosmog especially in densely populated urban centers. Sickness contributes to time off work and away from school, growing medical costs and a general poorer quality of life. Children are particularly vulnerable as are pregnant women and those with compromised immune systems. The presence of metal implants in the body (such as metal pins in bones) may concentrate the absorption of radiation at the location of implantation, inducing thermal effects from lower power densities than would ordinarily cause such harm (Massey 1979). Some implants, such as pace makers and deep brain stimulators for Parkinson’s disease, may malfunction and this can be fatal. In Switzerland about 5% of the population has EHS. If the same fraction of the population has EHS in the US that would come to a staggering 15 million people!

The symptoms following exposure to radio frequency radiation were labeled radiowave sickness and were first reported for those occupationally exposed in the former Soviet Union. These same symptoms are now referred to as electrohypersensitivity (EHS) and are experienced by a growing fraction of the population. They include . . .

“. . . headache, eyestrain and tearing, fatigue and weakness, vertigo, sleeplessness at night and drowsiness during the day, moodiness, irritability, hypochondria, paranoia, either nervous tension or mental depression and memory impairment. After longer periods of exposure, additional complaints may include sluggishness, inability to make decisions, loss of hair, pain in muscles and in the heart region, breathlessness, sexual

problems and even a decrease in lactation in nursing mothers. Clinically observed effects in persons voicing these complaints include trembling of the eyelids, fingers and tongue, increased perspiration of the extremities, [and] rashes . . .” (Massey, 1979).

1.5 In addition to sensitive people, Switzerland also identifies Places of Sensitive Use (German acronym is OMEN). These places include: living rooms; classrooms and kindergartens; hospitals and nursing homes; permanent jobs (where people spend more than 2.5 days per week); and playgrounds. For these OMEN sites, the Swiss government recommends that greater precaution be taken for long-term exposure to weak radiation. In these places, radiation from wireless microwave base stations (such as cordless phones or WLAN/WiFi) may exceed radiation from nearby cell phone base stations and hence these devices must generate emissions as low as possible. For more information visit http://www.bag.admin.ch/themen/strahlung/00053/index.html?lang=en

Item 2. Whether additional technology specific standards are needed for Smart Meters and other devices that are commonly found in and around homes, to ensure adequate protection from adverse health effects.

2.1       Technology specific standards are definitely needed for Smart meters as well as cordless phones, DECT baby monitors, wireless routers, and all of the other devices that emit radio frequency radiation.

Massey, in a report published by Duke Law Journal in 1979, identifies nine variables that need to be considered when determining the impact of microwave radiation. These are “power density, intensity and relative phase of all field components, specific frequency ranges, waveform characteristics, exposure regimes, specific occupations, level of control over exposed populations, individual differences (age, sex, health, specific predisposing factors) and presence of other environmental stressors.” The current FCC guidelines do NOT take these into consideration.

2.2 We have evidence that pulsed microwave frequencies, that are generated by WiFi and cordless phones are more harmful than continuous wave and yet this is not considered in the FCC guidelines (Reno 1975).

The key microwave emitting devices in the home/office/school environment are: Cordless phones (some are labeled DECT and others pulsed digital 2.4 GHz). These

radiate all the time even when no one is using them. They should be replaced by wired

phones or cordless phones currently available in Europe, which are “on-demand” phones that radiate only when the handset is not in the cradle of the base station. These phones are so dangerous that I recently submitted a Petition to the Auditor General of Canada to have DECT phones banned (Havas 2008).

The DECT baby monitor also radiates all the time, as does the receiver that is often carried on the Mother’s waist. Here we need a voice-activated baby monitor that is used in Europe.

Wireless Internet (WiFi or WLan) is not as common in Europe as they are in North America. There they prefer using wired service in the form of fiber optic and Ethernet connections. Germany hotels ask that you bring an Ethernet cables with you, as they don’t provide WiFi. The Swiss government is providing free fiber optics to schools provided they don’t install wireless routers.

2.3 An additional point I would like to make relates to dirty electricity.

Wires can act like antennas and the radiation produced by radio frequency generating devices can flow along and reradiate from wires both inside and outside the home. This contributes to dirty electricity and localized radiation exposure. Dirty electricity has been associated with cancers (Milham and Morgan 2008); health and behavior problems in schools (Havas and Olstad 2008); and both diabetes and multiple sclerosis (Havas 2006). From a human health perspective and to protect sensitive electronic equipment it is important to maintain good power quality and to prevent radiation from smart meters flowing along wires.

In conclusion, I have great concern regarding the current levels of microwave radiation in North America. Instead of promoting wireless technology, we should be promoting wired technology and reserving wireless for situations where wired in not possible (while one is traveling for example). Shortly after X-rays were discovered, they were used in shoe stores to determine shoe-size for young children. Fortunately, we recognized that X-rays were harmful and we restricted their use to essential medical diagnoses. We need to recognize that microwaves are also harmful and we cannot use this technology in a frivolous manner. With more frequencies being used, with the levels of radiation increasing, and with so little research on the long-term, low-level effects of this technology we are creating a potential time bomb. If smart meters are placed on every home, they will contribute significantly to our exposure and this is both unwise and unsafe.

References

Dodge, CH. 1969. Clinical and Hygienic Aspects of Exposure to Electromagnetic Fields: A Review of the Soviet and Eastern European Literature. Biological Effects and Health Implications of Microwave Radiation, Symposium Proceedings, Richmond, Virginia, September

17-19, 1969 (BRH/DBE 70-2) (PB 193 898). http://www.magdahavas.com/wordpress/wp- content/uploads/2010/08/Dodge_1969.pdf

Havas, M 2006. Electromagnetic Hypersensitivity: Biological effects of dirty electricity with emphasis on diabetes and multiple sclerosis. Electromagnetic Biology and Medicine, 25: 259-

268. http://www.electricalpollution.com/documents/Havas2006.pdf

Havas, M 2008. Request that first generation DECT Phones be Banned in Canada, Environment Petition, Auditor General of Canada, 15 pp. http://www.oagbvg. gc.ca/internet/English/pet_253_e_31629.html

Havas, M and A Olstad. 2008. Power quality affects teacher wellbeing and student behavior in three Minnesota Schools. Science of the Total Environment, Volume 402, Issues 2-3, 1

September 2008, pp. 157-162. http://www.electricalpollution.com/documents/08_Havas&Olstad_schools-1.pdf

Inglis, L.P. 1970. Why the double standard? – A critical review of Russian work on hazards of microwave radiation. IEEE International Symposium on Electromagnetic Compatibility, July 14-

16. 1970. http://www.magdahavas.com/wordpress/wpcontent/uploads/2010/08/Inglis.pdf

Massey, KA. 1979. The Challenge of Nonionizing Radiation: A Proposal for Legislation. Duke Law Journal, Volume 1979, No. 1. 86 pp. http://www.magdahavas.com/wordpress/wpcontent/ uploads/2010/10/Massey-1979.pdf

Milham, S and LL Morgan. 2008. A New Electromagnetic Exposure Metric: High Frequency Voltage Transients Associated With Increased Cancer Incidence in Teachers in a California School. Amer. J. Ind. Med. 8 pp. http://onlinelibrary.wiley.com/doi/10.1002/ajim.20598/abstract

Pollack, H. and J. Healer. 1967. Review of the Information on Hazards to Personnel from High- Frequency Electromagnetic Radiation. Institute for Defense Analyses, Research and Engineering Support Division. Internal Note N-451, IDA/HQ 67-6211, Series B, copy 5 of 15, 15 pages.http://www.magdahavas.com/wordpress/wpcontent/uploads/2010/07/Pollack_19671.pdf

Reno, VR. 1975. Some considerations concerning the use of magnetron generators in microwave biological research. Naval Aerospace Medical Research Laboratory, Pensacola, Florida. Approved for Public release. Distribution unlimited. 11 pp. http://www.magdahavas.com/wordpress/wpcontent/uploads/2010/09/Reno_Pulsed_Waves.pdf

Steneck, NH, HJ Cook, AJ Vander and GL Kane. 1980. The Origins of U.S. Safety Standards for Microwave Radiation. Science, Vol. 208, 13 June 1980. http://www.magdahavas.com/wordpress/wpcontent/uploads/2010/06/steneck_science_1980.pdf

Chronology:

On July 30, 2010, California State Assembly Member Jared Huffman (San Rafael) asked the California Council on Science and Technology (CCST) to provide an assessment of the safety of Smart Meters.

On August 16, 2010, CCST agreed to compile and assess the evidence available to address the following two issues:

1.    Whether FCC standards for Smart Meters are sufficiently protective of public health taking into account current exposure levels to radiofrequency and electromagnetic fields.

2.   Whether additional technology specific standards are needed for Smart Meters and other devices that are commonly found in and around homes, to ensure adequate protection from adverse health effects.

On October 4, 2010, I was invited to be part of a Technical Response Team and, as part of that team, I was asked to provide a written response to two key concerns mentioned above.

On October 12, 2010, I submitted my report to CCST.

On December 13, 2010, I was informed that CCST was not appending any documents to their report, nor were they making these documents available to others, but they were recognizing those who contributed.

On January 11, 2011, CCST released their report “Health Impacts of Radio Frequency from Smart Meters” on their website: http://www.ccst.us/news/2011/20110111smart.php. CCST is receiving public comments until January 31, 2011.

Samuel Milham, MD, MPH

To Lora Lee Martin:

Critique of CCST’s report, “Health Impacts of Radio Frequency from Smart Meters,”

From:

Samuel Milham MD, MPH

82181 Bergman Dr

Indio CA 92201

Dear Ms. Martin,

My name is Samuel Milham. I am a physician /epidemiologist , specializing in occupational medicine and in the health effects of electromagnetic fields (EMF). I was the first to document the link between occupational electromagnetic field exposure and cancer. My website www.sammilham.com has links to my recent papers, to my CV and to my new book, Dirty Electricity which presents evidence that most of the so-called diseases of civilization are due to EMF exposure not lifestyle.

Your report, unfortunately, reads as if were written by PG and E or Edison, and pays no attention at all to a very important EMF exposure variable, dirty electricity (high frequency voltage transients and harmonics).

Smart meters transmit their data via radio frequency (RF) either through the air or on utility wiring. The electronics of all transmitters operate on direct current (DC), which is obtained using inverters and switching power supplies in the meter which interrupt the grid AC current flow and generate dirty electricity which flows back to the grid on the 60 Hz AC throughout the substation service area. Interrupting current flow generates dirty electricity. Stetzer Electric markets a plug- in meter which measures dV/dT, the average rate of change of voltage on the wiring between 2 and 100 KHz, and capacitive filters to reduce the dirty electricity levels.

The grid was originally built so that all the electricity which flowed from the substation returned through the neutral wires. When people started using computers and other electrical devices with non-linear loads, the existing neutrals couldn’t handle the loads and fires resulted. The electrical building codes were revised to require more robust in- building neutrals, but the utilities got off the hook by instead of beefing up their neutrals, they simply tied the neutrals to the earth so that now, about 70% of the electricity delivered from the substation, returns there via the ground. The California PUC rule 33.2 forbids using the earth for return currents, but this didn’t stop PG and E or Edison from running wires down every other power pole connecting the neutral to the earth. Here is the PUC rule: (the bold font is mine)

General Order 95

Section III

Requirements for All Lines

33.2    Ground or Earth as a Conductor

Ground or earth shall not be used as a normal return or circuit conductor. In direct current supply systems or in single phase or polyphase supply systems, a neutral or any other conductor shall be used under normal use as a return or circuit conductor; however, the grounding of the neutral or any other conductor is not permitted as a normal return or circuit conductor. The neutral or any other conductor is permitted to be grounded only for the purposes of stabilization and protection.

Note:    Revised January 19, 1994 by Resolution SU–25.

Violation of this rule has created health problems in farm animals and families, and dirty electricity gets into our homes and offices and schoolsvia ground rods and electrically conductive plumbing. I have measured higher EMFs in homes with the electrical service turned off due to unbalanced current flow.

In the last few weeks, I have been contacted by two electrohypersensitive California women, both of whom had to move out of their homes because of illness as smart meters were being introduced into their neighborhoods, before smart meters were attached to their homes. A third east coast woman sent me an oscilloscope wave form obtained in her home with the electrical service turned off and no smart meter on her house. The neighborhood had smart meters deployed which used utility wiring to submit information to the substation. The frequency of the wave form was exactly that used to transmit smart meter information. (I’ll provide names and contact information on request). In the California cases the residences were too far from the transmitting smart meters to be affected by the RF. I believe that in all three cases, the damaging signal was dirty electricity in the wiring and the ground currents coming from the deployed meters.

My hypothesis is easy enough to test. Dirty electricity levels measured in homes, offices and schools should increase after the meters are deployed. Dirty electricity levels measured in the utility drops and in the earth will also increase as the meters are deployed. Since dirty electricity is a potent carcinogen (see attached paper and pp. 78-80 in my book), and causes numerous health problems, the only way to avoid a public health catastrophe is to send the smart meter information over existing telephone land lines or go back to the analog meters. I’m not making light of or ignoring the RF pollution caused by the smart meters, but think the dirty electricity may be a more serious and intractable problem.

My contact information is available on my website. Respectfully, Sam Milham MD, MPH

Lukas Margaritis, PhD, Professor of Cell Biology and Electron Microscopy

National and Kapodistrian

University of Athens

Faculty of Biology

Department of Cell Biology & Biophysics

Electromagnetic Biology Laboratory

Professor Lukas H. Margaritis

==================================================================

contact information available only in attached download

Address: Panepistimiopolis, Zografou,  Athens 157 84, GREECE

Athens, January 16th 2011

To whom it may concern

The California Council of Science and Technology has released a report on WIRELESS SMART METERS, in which any relation with health hazards has been bypassed. It is however “common secret” between the researchers in the field of electromagnetic biology that such a statement has absolutely no scientific validity for the following reasons.

  1. Life on the planet earth has evolved in the absence of such non-ionizing radiation and accumulating evidence suggests that no defence mechanisms have been evolved. Therefore there is no reference point for “safely limits”.
  2. All other devices mentioned in the report (mobile phones, microwave ovens, etc.) can be deliberately used at a safe situation (i.e. hands free utilization for mobile phone, keep safe distances from the microwave oven or the Wi-Fi when in use).
  3. Even if other wireless devices emit radiation in the same area, this does not mean that more can be installed with less radiation emission simply because there is strong evidence: a) for no threshold health limit, b) for cumulative health effects.
  4. It is not true (as mentioned in the report) that there is no evidence for mechanism on non-thermal. ROS formation is more and more shown to be a key first response cascading all rest effects (DNA damage, tumour formation, memory deficits, fatigue, sleep disorders, etc.).
  5. The argument that “more and more wireless devices will be used in daily life” is not and cannot be taken as obligatory. Who can support that the constitution, any constitution of any country should allow installations to take place (as the one with Smart Meters) against the rights for health of the citizens.
  6. The safety guidelines by ICNIRP are 12 years old, this by itself, after an enormous accumulation of research data implies that the threshold limits should have been updated, and they have not. In fact NO GUIDELINES FOR CONSTANT EXPOSURE HAVE BEEN ESTABLISHED SO FAR.

SOLUTION?

There may be a solution by optical fibers which are all over the place utilized in communication, so why not use them in this application as well.

Yours sincerely,

Lukas H. Margaritis

Professor of Cell Biology and Electron Microscopy

Adamantia F. Fragopoulou

Biologist, Researcher

Olle Johansson, Assoc. Prof.

Karolinska Institute, Sweden
Department of Neuroscience
Experimental Dermatology Unit

Stockholm, January 17, 2011

To whom it may concern

The California Council on Science and Technology, 1130  K Street, Suite 280, California 95814, USA, has recently released its report on wireless smart meters (“Health Impacts of Radio Frequency from Smart Meters”). In it, the possibility of any low-intensity health consequences of chronic exposure to pulsed microwave exposure is denied. However, in the current field of science, the present state-of-the-art regarding this issue is not so simple.

Wireless communication is now being implemented in our daily life in a very fast way. At the same time, it is becoming more and more obvious that the exposure to electromagnetic fields not only may induce acute thermal effects to living organisms, but also non-thermal effects, the latter often after longer exposures. This has been demonstrated in a very large number of studies and includes cellular DNA-damage, disruptions and alterations of cellular functions like increases in intracellular stimulatory pathways and calcium handling, disruption of tissue structures like the blood-brain barrier, impact on vessel and immune functions, and loss of fertility. Whereas scientists can observe and reproduce these effects in controlled laboratory experiments, epidemiological and ecological data derived from long-term exposures reflect in well-designed case-control studies the link all the way from molecular and cellular effects to the living organism up to the induction and proliferation of diseases observed in humans. It should be noted that we are not the only species at jeopardy, practically all animals and plants may be at stake. Although epidemiological and ecological investigations as such never demonstrate causative effects, due to the vast number of confounders, they confirm the relevance of the controlled observations in the laboratories.

Because the effects are reproducibly observed and links to pathology cannot be excluded, the precautionary principle should be in force in the implementation of this new technology within the society. This will be the only method to support the sustainability of these innovative wireless communication technologies. The February 2, 2000 European Commission Communication on the Precautionary Principle notes: “The precautionary principle applies where scientific evidence is insufficient, inconclusive or uncertain and preliminary scientific evaluation indicates that there are reasonable grounds for concern that the potentially dangerous effects on the environment, human, animal or plant health may be inconsistent with the high level of protection chosen by the EU”. Therefore, policy makers immediately should strictly control exposure by defining biologically-based maximal exposure guidelines also taking into account long-term, non-thermal effects, and including especially vulnerable groups, such as the elderly, the ill, the genetically and/or immunologically challenged, children and fetuses, and persons with the functional impairment electrohypersensitivity.

In November, 2009, a Scientific Panel comprised of international experts on the biological effects of electromagnetic fields met in Seletun, Norway, for three days of intensive discussion on existing scientific evidence and public health implications of the unprecedented global exposures to artificial electromagnetic fields (EMF) from telecommunications and electric power technologies. This meeting was a direct consequence of on-going discussions already from the mid-nineties, when cellular communications infrastructure began to rapidly proliferate, and stretching through, among many, the Benevento (2006), Venice (2008) and London (2009) Resolutions from this decade, and involving important conclusions drawn from the 600-page Bioinitiative Report published August 31, 2007, which was a review of over 2,000 studies showing biological effects from electromagnetic radiation at non-thermal levels of exposure, which partly was published subsequently in the journal Pathophysiology (Volume 16, 2009).

The Seletun Scientific Statement (2011) recommends that lower limits be established for electromagnetic fields and wireless exposures, based on scientific studies reporting health impacts at much lower exposure levels. Many researchers now believe the existing safety limits are inadequate to protect public health because they do not consider prolonged exposure to lower emission levels that are now widespread.

The body of evidence on electromagnetic fields requires a new approach to protection of public health; the growth and development of the fetus, and of children; and argues for strong preventative actions. These conclusions are built upon prior scientific and public health reports documenting the following:

1)         Low-intensity (non-thermal) bioeffects and adverse health effects are demonstrated at levels significantly below existing exposure standards.

2)         ICNIRP/WHO and IEEE/FCC public safety limits are inadequate and obsolete with respect to prolonged, low-intensity exposures.

3)         New, biologically-based public exposure standards are urgently needed to protect public health world-wide.

4)         It is not in the public interest to wait.

• EMR exposures should be reduced now rather than waiting for proof of harm before acting. This is in keeping with traditional public health principles, and is justified now given abundant evidence that biological effects and adverse health effects are occurring at exposure levels hundreds to thousands of times below existing public safety standards around the world.

• There is a need for mandatory pre-market assessments of emissions and risks before deployment of new wireless technologies. There should be convincing evidence that products do not cause health harm before marketing. Such decisions may have to be quickly revised given new evidence.

• The use of telephone lines (land-lines) or fiber optic cables for SmartGrid type energy conservation infrastructure is recommended. Utilities should choose options that do not create new, community-wide exposures from wireless components of SmartGrid-type projects. Future health risks from prolonged or repetitive wireless exposures of SmartGrid-type systems may be avoided by using fiber-optic cable. Energy conservation is endorsed but not at the risk of exposing millions of families in their homes to a new, involuntary source of wireless radiofrequency radiation, the effect of which on their health not yet known.

I encourage governments to adopt a framework of guidelines for public and occupational EMF exposure that reflect the Precautionary Principle. The Precautionary Principle states when there are indications of possible adverse effects, though they remain uncertain, the risks from doing nothing may be far greater than the risks of taking action to control these exposures. The Precautionary Principle shifts the burden of proof from those suspecting a risk to those who discount it — as some nations have already done. Precautionary strategies should be based on design and performance standards and may not necessarily define numerical thresholds because such thresholds may erroneously be interpreted as levels below which no adverse effect can occur.

You often hear about “safe levels” of exposure and that there is “no proof of health effects”, but my personal response to these seemingly reassuring statements is that it is very important to realize, from a consumer’s point of view, that “no accepted proof for health effects” is not the same as “no risk”. Too many times, ‘experts’ have claimed to be experts in fields where actually the only expert comment should have been: “I/we just do not know”. Such fields were e.g. the DDT, X-ray, radioactivity, smoking, asbestos, BSE, heavy metal exposure, depleted uranium, etc., etc., etc., where the “no risk”-flag was raised before true knowledge came around. Later on, the same flag had to be quickly lowered, many times after enormous economic costs and suffering of many human beings. Along those lines, it is now (regarding “the protection from exposure to electromagnetic fields” issue) very important to clearly identify the background and employment (especially if they sit, at the same time, on the industry’s chairs) of every ‘expert’ in different scientific committees, and likewise. It is, of course, very important (maybe even more important?) to also let ‘whistleblowers’ speak at conferences, to support them with equal amounts (or even more?) of economical funding as those scientists and other ‘experts’ who, already from the very beginning, have declared a certain source or type of irradiation, or a specified product, to be 100% safe.

In the case of “protection from exposure to electromagnetic fields”, it is thus of paramount importance to act from a prudence avoidance/precautionary principle point of view. Anything else would be highly hazardous! Total transparency of information is the key sentence here, I believe consumers are very tired of always having the complete truth years after a certain catastrophe already has taken place. For instance, it shall be noted, that today’s recommendation values for wireless systems, the SAR-value, are just recommendations, and not safety levels. Since scientists observe biological effects at as low as 20 microWatts/kg, is it then really safe to irradiate humans with 2 W/kg (i.e., with 100,000 times stronger radiation!), which is the recommendation level for us? And, furthermore, it is very strange to see, over and over again, that highly relevant scientific information is suppressed or even left out in various official documents, as high up as at the governmental level of society. This is not something that the consumers will gain anything good from, and, still, the official declaration or explanation (from experts and politicians) very often is: “If we (=the experts) would let everything out in the open, people would be very scared and they would panic.” Personally, I have never seen this happen, but instead I have frequently seen great disappointment from citizens who afterwards have realized they have been fooled by their own experts and their own politicians.

Another misunderstanding is the use of scientific publications (as the tobacco industry did for many years) as ‘weights’ to balance each other. But you can NEVER balance a report showing a negative health effect with one showing nothing! This is a misunderstanding which, unfortunately, is very often used both by the industrial representatives as well as official authorities. The general audience, naturally, easily is fooled by such an argumentation, but if you are bitten by a deadly poisonous snake, what good does it make for you that there are 100 million harmless snakes around?

In many commentaries, debate articles and public lectures – for the last 20-30 years – I have urged that completely independent research projects must be inaugurated immediately to ensure our public health. These projects must be entirely independent of all types of commercial interests; public health cannot have a price-tag! It is also of paramount importance that scientists involved in such projects must be free of any carrier considerations and that the funding needed is covered to 100%, not 99% or less. This is the clear responsibility of the democratically elected body of every country.

Many smart meters are close to beds, kitchens, playrooms, and similar locations. These wireless systems are never off, and the exposure is not voluntary. The smart meters are being forced on citizens everywhere. Based on this, the inauguration of smart meters with grudging and involuntary exposure of millions to billions of human beings to pulsed microwave radiation should immediately be prohibited until ’the red flag’ can be hauled down once and for all.

With my very best regards,

Yours sincerely,
Olle Johansson, Assoc. Prof.,
The Experimental Dermatology Unit,
Department of Neuroscience,
Karolinska Institute,
171 77 Stockholm,
Sweden
&
Professor,
The Royal Institute of Technology,
100 44 Stockholm,
Sweden

David O. Carpenter, M.D.

University at Albany State University of New York
Institute for Health and the Environment
and
Department of Environmental Health Sciences
School of Public Health

This is a report on the review of the California Council on Science and Technology document, “Health Impacts of Radiofrequency from Smart Meters”.  I am a public health physician and former Dean of the School of Public Health at the University at Albany.  I have been involved in review and analysis of studies on electromagnetic fields, including radiofrequency fields, for many years.  I served as the Executive Secretary to the New York State Powerlines Project in the 1980s, and have published several reviews on the subject and have edited two books.  In addition I was invited to present to the recent President’s Cancer Panel on the subject of powerline and radiofrequency fields and cancer.

This document is not an accurate description of the state of the science on the issue of radiofrequency fields, and is full of inaccuracies.  My specific concerns are as follows:

  1. The benefit of the smart meters is entirely to the utilities, and is economic in nature.  If they install smart meters they can fire those individuals who at present are employed to go around reading meters.  Thus this is a job-killing proposal, and will increase unemployment in a state that already has too much.
  2. When a smart meter is installed residents have no choice in the matter nor ability to avoid exposure.  But every individual has the option to use or not use other personal wireless devices, until more is known about health consequences of chronic RF exposure. There is a major difference between an exposure which an individual chooses to accept and one that is forced on individuals who can do nothing about it.
  3. The statement “The potential for behavioral disruption from increase body tissue temperatures is the only biological health impact that has been consistently demonstrated and scientifically proven to result from absorbing RF within the band of the electromagnetic spectrum that smart meters use” is totally wrong.   In the first place there are many adverse health effects other than “behavioral disruption” demonstrated as a result of tissue heating.  The evidence for increased risk of brain tumors, acoustic neuromas and parotid gland tumors in individuals who have used a cell phone for 10 years or more is consistent, and the tumors occur predominantly on the side of the head where the phone is used.  There is also strong and consistent evidence for increased risk of leukemia in individuals who live near to high power AM radio transmission towers, even though this report characterizes such exposures as being “quite low” and show in Figure 7 that they are lower than the RF fields from smart meters.
  4. The statement “The scientific consensus is that body temperatures must increase at least 1oC to lead to potential biological impacts from the heat” is totally wrong, and makes it obvious that no persons with medical or biological expertise participated in this report.  Every enzyme system in the body is exquisitely sensitive to temperature, and increases activity by even a fraction of a degree increase in temperature.  In fact all RF generates heat, and what is defined as “non-thermal” is only a function of our ability to measure the temperature increase.
  5. The statement “While concerns of brain cancer associated with mobile phone usage persist, there is currently no definitive evidence linking cell phone usage with increased incidence of cancer” is incorrect.  The evidence is strong and consistent among studies looking at long-term and intensive use of cell phones.  The AM radio studies mentioned above are also relevant, particularly because like smart phones radio transmission towers give whole body radiation, not just to the head.
  6. The statement “There currently is no conclusive scientific evidence pointing to a non-thermal cause-and-effect between human exposure to RF emissions and negative health impacts  is
    inaccurate, and depends totally on what one defines as conclusive”.  In biology and medicine there is nothing that is 100% proven. We rely on statistical significance and weight of evidence when drawing conclusions about health effects.  When one uses these definitions there is conclusive scientific evidence for adverse health effects in humans.
  7. The evidence for adverse effects of radiofrequency radiation is currently strong and grows stronger with each new study.  Wired meters with shielded cable do not increase exposure.  The report clearly indicates that “smart meters could conceivably be adapted to non-wireless transmission of data.  However, retrofitting millions of smart meters with hard-wired technology could be difficult and costly.”  Clearly the answer to this dilemma is not to install wireless smart meters to begin with.

Thank you for the opportunity to comment on this faulty report, and on the general issue of smart meters.  Their use is unwise from both a public health point of view, which is where my expertise lies, but and also from a purely short and long-term economic point of view.

Yours sincerely,

David O. Carpenter, M.D.

Director, Institute for Health and the Environment

University at Albany

Elihu Richter, MD, MPH

Hebrew University-Hadassah

School of Public Health and Community Medicine

Unit of Occupational and Environmental Medicine

http://www.md.huji.ac.il/depts/occenvmed/

contact information available only in attached download

26 January, 2011

Susan Hackwood, PhD

Executive Director

California Council on Science and Technology

Lora Lee Martin, Director

Strategic Policy Initiatives and Government Affairs

California Council on Science and Technology

Subject: Letter of Comment on Smart Meter Report

I have been invited by colleagues to submit my Commentary on CCST Report and Recommendations for Smart Meters using RF. My comments are based on the information summarized in the Bioinitiative Report and the Seletun Reports, as well as the other reports in the recent scientific literature, The broader context for my commentary are the consequences of our past failures in environmental epidemiology to heed early warnings from other many population wide exposures in yesteryear, notably lead.

Personal Background: I am a medical epidemiologist who has assessed source-exposure-effect relationships for many chemical and physical agents over the past 40 years. This work has included work on lead, asbestos and smoking, pesticides, solvents, air pollution, and mixed exposures and ionizing radiation. Since the late 1980’s I served as Head of the Unit of Occupational and Environmental Medicine in Hebrew University-Hadassah School of Public Health and Community Medicine in Jerusalem Israel. I have also been involved in issues having to do with the medical ethics in public health, and served for several years as Chairman of the Ethics and Philosophy Committee of the International Society for Environmental Epidemiology and I am a member of the Collegium Ramazzini. I have published more than 100 scientific papers in the peer reviewed literature. Since the 1980′s, I have had the opportunity to assess the case for a cause effect relationship with many workers with past cancer and past severe exposures to RF/MW, often after short latent periods. I have also supervised projects assessing community exposures to RF/MW and ELF in Jerusalem. I have reported on cases of brain cancer in individuals with latency periods of less than 10 years and am currently writing an investigation of a cluster of cancer in workers with extremely high occupational exposures to RF. I helped draft the Benevento and Seletun statements. In recent years, I have been particularly active assessing the use and scope of the Precautionary Principle in examining the anticipated risks from alternative technologies.

  1. Smart grid networks, if using RF, will generate 24/7 round the clock ubiquitous involuntary indoor exposures to RF – in the everyday background environment of everyone in California in human habitats. The background exposures produced by these grids will be substantially greater than those from point source WI-FI routers, microwave ovens and cell phones. These whole body exposures, though perhaps below levels of current regulatory standards, (INCRIP-WHO, and IEEE), will exceed cumulative time weighted exposures producing the above outcomes, based on the literature.
  2. Based on the evidence in peer reviewed studies on the effects on these endpoints and the exposure projections in Sage Associates’ landmark report (see Sage, http://sagereports.com/smart-meter-rf/docs/Table7-8ElectricMeters_R1000_TA1-90Final.pdf ) this project exposes large percentages of the general population to highly alarming involuntary exposure risk scenarios, taking into account an array of modifying factors e.g. background exposures, distance, reflection, and factors influencing access to exposure areas.
  3. Since the publication of the Benevento Resolution and the BioInitiative Report, the body of evidence concerning health risks from exposures to RF continues to accumulate. In particular from cell phone use. Cell phone use involves the delivery of a high concentration of non-ionizing radiation to the skull and brain for relatively brief periods of time over a 24 hour period as result of voluntary decisions by users—a situation far less aggressive to the general population than involuntary exposure from the proposed Smart Meters. Models for predicting penetration into the whole body are now available, based on those developed by Gandhi and by Kuster. These models draw attention in particular to the risks from exposure to the young.
  4. The exposures from Smart Meters are the equivalent of exposure of the entire population—the young, the old, the newborn, the unborn, and the sick, to environmental tobacco smoke, even if most members of the population do not smoke.
  5. There is a huge body of evidence to refute the claim the so-called “hot muffin theory” that there are no effects from sub-thermal exposures to NIR, and specifically RF/MW (Benevento Statement, BioInitative Report, London Report) The effects pertain to ROS- Reactive Oxygen Species, cellular changes, effects on DNA, and neurobehavioral effects– e.g. deficits in memory, mood changes, fatigue, headache, as well as electro hypersensitivity and cancer, and effects on those with electronic medical implants. It is important to note that there are also concerns about the production of dirty electricity, itself a risk factor for many of these outcomes (Milham).
  6. Models of carcinogenicity or exposures to toxic and physical agents and cancer postulate that we cannot be certain there is a threshold (based on the DNA single hit model). These models also postulate roughly linear dose response relationships and recognize groups and age windows for special risks—e.g. foetuses, newborns, persons who are immunocompromised and those with sensitivities on the basis of mechanisms which are still poorly understood. For populations, it is probable that similar dose response models for exposure-risk relationships apply even though mechanisms involve resonance models of intensity and frequency.
  7. It is fair to say that we are no longer talking about mere precaution of uncertain risk, but about prevention of highly probable and known risks. Based on the accumulating evidence, it is now fairly certain that there will be widespread adverse public health impacts. What remains uncertain is how many will be affected, and whether there are time weighted intensity of exposure thresholds, below which there will be absence of risk.
  8. The most plausible scenario is that there will be ‘small’ increases in individual risk for the incidence of occurrence (e.g. cancer) or incidence and severity (e.g. neurobehavioral effects), applied to the entire population from these networks/ large population wide increases in absolute numbers of people with adverse outcomes. The epidemiologist Geoffrey Rose articulated the principle that small increases in so-called sub-threshold exposures result in many more individuals with illness in the entire population than high exposures delivered to small numbers of people. This principle applies to the scenario of population-wide effects from exposures to RF from networks of Smart Meters and concerns about dirty electricity.
  9. Were these population-wide exposures to smart meters to be part of a project carried out in a medical setting, to test the risks and benefits of a new technology on human health and well being, it would be rejected by a Medical Institutional Review Board on ethical grounds as an unethical exercise in human experimentation.
  10. The risks we are assessing today from exposure to RFMW and dirty electricity from Smart Meters placed everywhere recalls the story of population-wide exposure to lead in gasoline – a subject concerning which I have much direct personal experience. In the 1970s, a mere 35 yrs ago, we were arguing as to whether or not an everyday blood lead level of 30ug/dl was a health risk. By 1979, that threshold dropped to 20ug/dl and thereafter through the 1980s to 10ug/dl for children, and now we are not certain whether there is a threshold below which there are no discernable adverse neurobehavioral effects, especially for in utero and newborn exposures. We now know, in retrospect, that the entire urban population, notably children, were receiving exposures which were impairing their IQ, emotional well being, and long term growth and development. These findings led to the elimination of lead from gasoline. In retrospect, we were not heeding the early warnings regarding an impending population-wide hazard with disastrous effects. I suggest that in the case of population-wide exposure to RF, the situation is similar, with one exception: The warnings may no longer be early.
  11. Population-wide exposure to man-made NIR represents a scenario relatively new in the history of biology. It is difficult to assess risks from these new exposures and their frequencies and wave patterns using experience based on exposure to background naturally occurring NIR. Instead, we are required to rely on experimental studies and epidemiology of exposure-effect relationships, using endpoints such as effects on stem cells, leaks from the blood brain barrier, as well neurological, cardiac and cancer endpoints. In addition, there are additional vulnerabilities to the eyes and to the testes.
  12. I warn that we may be on the cusp of a similar scenario here with regard to community wide exposures to RF/MW and dirty electricity from Smart Meters —with one exception: there are safe alternatives.
  13. The Precautionary Principle, in its various formulations, specifies that where there is uncertainty concerning the possibility of health risks from a new technology, the costs of doing nothing to prevent the exposure (e.g. a false negative) may be greater than a false positive (taking preventive action). I add that in applying the Precautionary Principle, we are required to weigh the risks and benefits from 3 options: doing nothing (i.e. no Smart Meters), and doing something (Smart Meters with RF) or a different kind of Meters using fiberoptics. We recognize that doing nothing carries itself certain risk having to do with the operations of the electrical ssgrid system.
  14. But alternative technology- smart meters powered by fiber optics, which are without known risk, can be used to achieve the same objective.

  15. There is no excuse for avoiding this investment with a permanent enduring protection for the public in avoiding and not introducing fiber optics. For reasons just stated, it will be bad ethics and bad technology and, possibly wanton negligence, recklessness and incompetence to wilfully forego the last option.

I thank the Commission for the opportunity to submit my comments.

Elihu D Richter MD, MPH (Assoc Professor)

References:

1. BioInitiative Working Group, Cindy Sage and David O. Carpenter, Editors. BioInitiative Report: A Rationale for a Biologically-based Public Exposure Standard for Electromagnetic Fields (ELF and RF). www.bioinitiative.org. August 31, 2007.

2. Pathophysiology Journal, Special Issue 16: Volumes 1 and 2, 2009. Elsevier Press. There are chapters on low-intensity radiofrequency and wireless radiation health effects based on scientific literature from the realms of genotoxicity, genomics and proteomics, neurology, blood-brain barrier effects, stress (heat shock) proteins, immunology and inflammatory diseases, cancer and public health consequences of ignoring warnings given global proliferation of wireless exposures at billions of times greater levels than earth and humans evolved with.

3. WHO Research Agenda, 2010. WHO research agenda for radiofrequency fields, © World Health Organization 2010

4. REFLEX, 2004. Risk Evaluation of Potential Environmental Hazards from Low Frequency Electromagnetic Field Exposure Using Sensitive in vitro Methods.

5. Markova E, Malmgren LOG, Belyaev IY. 2009. Microwaves from mobile phones inhibit 53PB1 focus formation in human stem cells stronger than in differentiated cells: Possible mechanistic link to cancer risk.  Environmental Health Perspectives On-line. 22 October 2009. doi:10.1289/ehp.0900781

6. Belyaev IY, Markovà E, Hillert L, Malmgren LO, Persson BR. 2009. Microwaves from UMTS/GSM mobile phones induce long-lasting inhibition of 53BP1/gamma-H2AX DNA repair foci in human lymphocytes. Bioelectromagnetics 30: 129-141

7. Sage C, Carpenter D.O. 2009. Public Health Implications of Wireless Technologies. Pathophysiology 16: 233–246.

8. Capri M, Scarcella E, Fumelli C, Bianchi E, Salvioli S, Mesirca P, Agostini C, Antolini A, Schiavoni A, Castellani G, Bersani F, Franceschi C. 2004. In vitro exposure of human lymphocytes to 900 MHz CW and GSM modulated radiofrequency: studies of proliferation, apoptosis and mitochondrial membrane potential. Radiation Research 162: 211-218.

9. Nittby H, Grafstrom G, Eberhardt JL, Malmgren L, Brun A, Persson BRR, Salford LG. 2008. Radiofrequency and Extremely Low-Frequency Electromagnetic Field Effects on the Blood-Brain Barrier. Electromagnetic Biology and Medicine 27:103–126.

10. Velizarov S, Raskmark P, Kwee S. 1999. The effects of radiofrequency fields on cell proliferation are non-thermal, Bioelectrochem Bioenerg 1999; 48: 177-180

11. Wolke S, Neibig U, Elsner R, Gollnick F, Meyer R. 1996. Calcium homeostasis of isolated heart muscle cells exposed to pulsed high-frequency electromagnetic fields, Bioelectromagnetics 17:144-153

12. Zwamborn APM, Vossen SHJA, van Leersum BJAM, Ouwens MA, Mäkel WN. 2003. Effects of global communication system radio-frequency fields on well-being and cognitive functions of human subjects with and without subjective complaints, TNO-report FEL-03-C148; 148:1-89

13. Sage Associates, 2011. Assessment of Radiofrequency Microwave Radiation Emissions from Smart Meters. http://sagereports.com/smart-meter-rf/

14. Grandjean P, Bellinger D, Bergman A, Cordier S, Davey-Smith G, Eskenazi B, Gee D, Gray K, Hanson M, van den Hazel P, Heindel JJ, Heinzow B, Hertz-Picciotto I, Hu H, Huang T, Jensen TK, Landrigan PJ, McMillen C, Murata K, Ritz Schoeters G, Skakkebaek NE, Skerfving S, Weihe P. 2007. The Faroes Statement: Human Health Effects of Developmental Exposure to Chemicals in Our Environment, Nordic Pharmacological Society. Basic & Clinical Pharmacology & Toxicology 102:73–75

Table 26: Kitchen BBB 1,4

One Meter Table A33 Table A34 Table A35 Table A36
Duty Cycle 60% 100% 1000% 2000%
Reflection* Reflection Reflection Reflection
1% 0.2 0.3 10.2* 37.3**
5% 1.1* 1.7* 51.1** 186**
10% 2.2* 3.4* 102** 373**
20% 4.3 6.8* 204** 745**
30% 6.5* 10.1** 307** 1118**
40% 8.7** 13.5** 409** 1490**
50% 10.8** 16.9** 511** 1863**
60% 13** 20.3** 613** 2235**
70% 15.1** 23.7** 716** 2608**
80% 17.3** 27** 818** 2980**
90% 19.5** 30.4** 920** 3353**
100% 21.6** 33.8** 1022** 3726**
Four meters Table A37 Table A38 Table A39 Table A40
Duty Cycle 60% 100% 1000% 2000%
Reflection* Reflection Reflection Reflection
1% 0.6* 0.9* 26** 94.6**
5% 2.8* 4.3* 129** 473**
10% 5.5* 8.6** 260** 946**
20% 11** 17.2** 519** 1892**
30% 16.5** 25.7** 779** 2837**
40% 22** 34.3** 1038** 3783**
50% 27.5** 42.9** 1298** 4729**
60% 32.9** 51.5** 1557** 5675**
70% 38.4** 60.1** 1817** 6621**
80% 43.9** 68.6** 2076** 7566**
90% 49.4** 77.2** 2336** 8512**
100% 54.9** 85.8** 2595** 9458**

**Exceeds 8 uW/cm2

*Exceeds between 0.4 and 8 uW/cm2

Table 25: Kitchen Markova 92.5 1C

One Collector Table A41 Table A42 Table A43 Table A44
Duty Cycle 60% 100% 1000% 2000%
Reflection Reflection Reflection Reflection
1% 0.6 uW/cm2 1 28.8 105*
5% 3.1 4.8 144* 525*
10% 6.1 9.5 288* 1049*
20% 12.2 19 576* 2098*
30% 18.3 28.6* 864* 3148*
40% 24.4 38.1* 1152* 4197*
50% 30.5 47.6* 1439* 5246*
60% 36.5 57.1* 1727* 6295*
70% 42.6 66.6* 2015* 7344*
80% 48.7 75.1* 2303* 8393*
90% 54.8 85.7* 2591* 9243*
100% 60.9 95.2* 2879* 10492*
One Collector + 3 S Table A45 Table A46 Table A47 Table A48
Duty Cycle 60% 100% 1000% 2000%
Reflection Reflection Reflection Reflection
1% 0.9 uW/cm2 1.5 45 162*
5% 4.7 7.4 223* 811*
10% 9.4 14.7 445* 1622*
20% 18.8 29.4 890* 3245*
30% 28.3 44.2 1336* 4867*
40% 37.7 58.9 1781* 6490*
50% 47.1 73.6 2226* 8112*
60% 56.5 88.3 2671* 9734*
70% 65.9 103* 3116* 11357*
80% 75.4 118* 3561* 12979*
90% 84.8 132* 4006* 14602*
100% 94.2* 147* 4452* 16224*

*Exceeds 92.5 uW/cm2

Table 24: Kitchen 92.5 Markova

One Meter Table A33 Table A34 Table A35 Table A36
Duty Cycle 60% 100% 1000% 2000%
Reflection Reflection Reflection Reflection
1% 0.2 0.3 10.2 37.3
5% 1.1 1.7 51.1 186
10% 2.2 3.4 102* 373*
20% 4.3 6.8 204* 745*
30% 6.5 10.1 307* 1118*
40% 8.7 13.5 409* 1490*
50% 10.8 16.9 511* 1863*
60% 13 20.3 613* 2235*
70% 15.1 23.7 716* 2608*
80% 17.3 27 818* 2980*
90% 19.5 30.4 920* 3353*
100% 21.6 33.8 1022* 3726*
Four Meters Table A37 Table A38 Table A39 Table A40
Duty Cycle 60% 100% 1000% 2000%
Reflection Reflection Reflection Reflection
1% 0.6 0.9 26 94.6*
5% 2.8 4.3 129* 473*
10% 5.5 8.6 260* 946*
20% 11 17.2 519* 1892*
30% 16.5 25.7 779* 2837*
40% 22 34.3 1038* 3783*
50% 27.5 42.9 1298* 4729*
60% 32.9 51.5 1557* 5675*
70% 38.4 60.1 1817* 6621*
80% 43.9 68.6 2076* 7566*
90% 49.4 77.2 2336* 8512*
100% 54.9 85.8 2595* 9458*

*Exceeds 92.5 uW/cm2

Table 23: Nursery 0.1 Kundi 1C

As reported in Khurana et al, 2010 in the International Journal of Environmental Occupational Health 16:263-267; Kundi and Hutter, 2009, Pathophysiology 16: 123-135 and the BioInitiative Report, 2007, Chapters 1 and 17.

One Collector Table A33 Table A34 Table A35 Table A36
Duty Cycle 60% 100% 1000% 2000%
Reflection Reflection Reflection Reflection
1% 4 6.2 187 680
5% 20 30.8 933 3399
10% 40 61.7 1865 6798
20% 79 123 3730 13596
30% 118 185 5596 20394
40% 158 247 7461 27192
50% 197 308 9326 33990
60% 237 370 11191 40788
70% 276 432 13056 47586
80% 316 493 14922 54384
90% 355 555 16787 61182
100% 395 617 18652 67980
1C + 3 SM Table A37 Table A38 Table A39 Table A40
Duty Cycle 60% 100% 100% 2000%
Reflection Reflection Reflection Reflection
1% 7.4 11.5 348 1267
5% 36.8 57.5 1738 6334
10% 73.5 115 3476 12668
20% 147 230 6952 25337
30% 221 345 10428 38005
40% 294 460 13904 50674
50% 368 575 17380 63342
60% 441 689 20855 76010
70% 515 804 24331 88679
80% 588 919 27807 101347
90% 662 1034 31283 114015
100% 735 1149 34759 126684

All exposure levels exceed those identified in Khurana et al, 2010; Kundi and Hutter, 2009 and the BioInitiative Report (2007) to be associated with increased risk of adverse neurological symptoms (headache, sleep disruption, restlessness, tremor, cognitive impairment tinnitus), increased cancer risk or heart problems (arrythmias, altered heart rhythm, palpitations). These effects are reported in studies of populations living at distances < 500 meters from base stations, and at levels at or over 0.05-0.1 uW/cm2, but not at RF levels below 0.05 – 0.1 uW/cm2 in healthy populations.

Table 22 Nursery 0.1 Kundi 1.4

As reported in Khurana et al, 2010 in the International Journal of Environmental Occupational Health 16:263-267; Kundi and Hutter, 2009, Pathophysiology 16: 123-135 and the BioInitiative Report, 2007, Chapters 1 and 17.

One Meter Table A17 Table A18 Table A19 Table A20
Duty Cycle 60% 100% 1000% 2000%
Reflection Reflection Reflection Reflection
1% 1.4 2.2 66.2 241
5% 7 11 331 1227
10% 14 21.9 662 2414
20% 28 43.8 1324 4828
30% 42 65.7 1986 7242
40% 56.1 87.6 2649 9655
50% 70.1 109 3312 12069
60% 84.1 131 3974 14483
70% 98.1 153 4636 16897
80% 112 175 5299 19311
90% 126 197 5961 21175
100% 140 218 6623 24139
Four Meters Table A21 Table A22 Table A23 Table A24
Duty Cycle 60% 100% 1000% 2000%
Reflection Reflection Reflection Reflection
1% 4.9 7.5 227 828
5% 24 37.6 1137 4142
10% 48.1 75.1 2273 8284
20% 96.2 150 4546 16569
30% 144 225 6819 24853
40% 192 301 9092 33137
50% 240 376 11365 41421
60% 289 451 13638 49705
70% 337 526 15911 57990
80% 385 601 18184 66274
90% 433 676 20457 74558
100% 481 751 22730 82843

All exposure levels exceed those identified in Khurana et al, 2010; Kundi and Hutter, 2009 and the BioInitiative Report (2007) to be associated with increased risk of adverse neurological symptoms (headache, sleep disruption, restlessness, tremor, cognitive impairment tinnitus), increased cancer risk or heart problems (arrythmias, altered heart rhythm, palpitations). These effects are reported in studies of populations living at distances < 500 meters from base stations, and at levels at or over 0.05-0.1 uW/cm2, but not at RF levels below chronic RF exposure levels of 0.05 – 0.1 uW/cm2 in healthy populations.

Table 21: Nursery BBB 1C

One Collector Table 25 Table A26 Table A27 Table A28
Duty Cycle 60% 100% 1000% 2000%
Reflection Reflection Reflection Reflection
1% 4.0 uW/cm2 6.2 187* 680*
5% 19.7* 30.8* 933* 3399*
10% 39.5* 61.7* 1865* 6798*
20% 78.9* 123* 3730* 13596*
30% 118* 185* 5596* 20394*
40% 158* 247* 7461* 27192*
50% 197* 308* 9326* 33990*
60% 237* 370* 11191* 40788*
70% 276* 432* 13056* 47586*
80% 316* 493* 14922* 54384*
90% 355* 555* 16787* 61182*
100% 395* 617* 18652* 67980*
One Collector + 3 Meters Table A29 Table A30 Table A31 Table A32
Duty Cycle 60% 100% 1000% 2000%
Reflection Reflection Reflection Reflection
1% 7.4 uW/cm2 11.5* 348* 1267*
5% 36.8* 57.5* 1738* 6334*
10% 73.5* 115* 3476* 12668*
20% 147* 230* 6952* 25337*
30% 221* 345* 10428* 38005*
40% 294* 460* 13904* 50674*
50% 368* 575* 17380* 63342*
60% 441* 689* 20855* 76010*
70% 515* 804* 24331* 88679*
80% 588* 919* 27807* 101347*
90% 662* 1034* 31283* 114015*
100% 735* 1149* 34759* 126684*

*Exceeds 8 uW/cm2

Table 20: Nursery BBB 1.4

One Meter Table A17 Table A18 Table A19 Table A20
Duty Cycle 60% 100% 1000% 2000%
Reflection* Reflection Reflection Reflection
1% 1.4* 2.2* 66.2** 241**
5% 7* 11** 331** 1227**
10% 14** 21.9** 662** 2414**
20% 28** 43.8** 1324** 4828**
30% 42** 65.7** 1986** 7242**
40% 56.1** 87.6** 2649** 9655**
50% 70.1** 109** 3312** 12069**
60% 84.1** 131** 3974** 14483**
70% 98.1** 153** 4636** 16897**
80% 112** 175** 5299** 19311**
90% 126** 197** 5961** 21175**
100% 140** 218** 6623** 24139**
Four Meters Table A21 Table A22 Table A23 Table A24
Duty Cycle 60% 100% 1000% 2000%
Reflection* Reflection Reflection Reflection
1% 4.9* 7.5* 227** 828**
5% 24** 37.6** 1137** 4142**
10% 48.1** 75.1** 2273** 8284**
20% 96.2** 150** 4546** 16569**
30% 144** 225** 6819** 24853**
40% 192** 301** 9092** 33137**
50% 240** 376** 11365** 41421**
60% 289** 451** 13638** 49705**
70% 337** 526** 15911** 57990**
80% 385** 601** 18184** 66274**
90% 433** 676** 20457** 74558**
100% 481** 751** 22730** 82843**

*Exceeds between 0.4-8

**Exceeds 8 uW/cm2

Table 19: Nursery 92.5

OneCollector Table A25 Table A26 Table A27 Table A28
Duty Cycle 60% 100% 1000% 2000%
Reflection Reflection Reflection Reflection
1% 4.0 uW/cm2 6.2 187 680*
5% 19.7 30.8 933* 3399*
10% 39.5 61.7 1865* 6798*
20% 78.9 123* 3730* 13596*
30% 118* 185* 5596* 20394*
40% 158* 247* 7461* 27192*
50% 197* 308* 9326* 33990*
60% 237* 370* 11191* 40788*
70% 276* 432* 13056* 47586*
80% 316* 493* 14922* 54384*
90% 355* 555* 16787* 61182*
100% 395* 617* 18652* 67980*
One C+ 3 SM Table A29 Table A30 Table A31 Table A32
Duty Cycle 60% 100% 1000% 2000%
Reflection Reflection Reflection Reflection
1% 7.4 uW/cm2 11.5 348* 1267*
5% 36.8 57.5 1738* 6334*
10% 73.5 115* 3476* 12668*
20% 147* 230* 6952* 25337*
30% 221* 345* 10428* 38005*
40% 294* 460* 13904* 50674*
50% 368* 575* 17380* 63342*
60% 441* 689* 20855* 76010*
70% 515* 804* 24331* 88679*
80% 588* 919* 27807* 101347*
90% 662* 1034* 31283* 114015*
100% 735* 1149* 34759* 126684*

*Exceeds 92.5 uW/cm2

Table 18: Nursery 92.5 Markova

One Meter Table A17 Table A18 Table A19 Table A20
Duty Cycle 60% 100% 1000% 2000%
Reflection Reflection Reflection Reflection
1% 1.4 2.2 66.2 241*
5% 7 11 331* 1227*
10% 14 21.9 662* 2414*
20% 28 43.8 1324* 4828*
30% 42 65.7 1986* 7242*
40% 56.1 87.6 2649* 9655*
50% 70.1 109* 3312* 12069*
60% 84.1 131* 3974* 14483*
70% 98.1* 153* 4636* 16897*
80% 112* 175* 5299* 19311*
90% 126* 197* 5961* 21175*
100% 140* 218* 6623* 24139*
Four Meters Table A21 Table A22 Table A23 Table A24
Duty Cycle 60% 100% 1000% 2000%
Reflection Reflection Reflection Reflection
1% 4.9 7.5 227* 828*
5% 24 37.6 1137* 4142*
10% 48.1 75.1 2273* 8284*
20% 96.2* 150* 4546* 16569*
30% 144* 225* 6819* 24853*
40% 192* 301* 9092* 33137*
50% 240* 376* 11365* 41421*
60% 289* 451* 13638* 49705*
70% 337* 526* 15911* 57990*
80% 385* 601* 18184* 66274*
90% 433* 676* 20457* 74558*
100% 481* 751* 22730* 82843*

Exceeds 92.5 uW/cm2

Table 17: FCC Viol 3 1C Data

One Collector Table A9 Table A10 Table A11 Table A12
Duty Cycle 60% 100% 1000% 2000%
571 limit Reflection Reflection Reflection Reflection
1% 53 83 2507 9137*
10% 530 829 25070* 91372*
20% 1061 1658 50140* 182743*
30% 1591 2486 75211* 274115*
40% 2122 3315 100281* 365486*
50% 2652 4144* 125351* 456858*
60% 3182 4973* 150421* 548229*
70% 3713 5801* 175491* 639601*
80% 4243* 6630* 200562* 730972*
90% 4774* 7459* 225632* 822344*
100% 5304* 8288* 250702* 913715*
One C + 3 SM Table A13 Table A14 Table A15 Table A16
Duty Cycle 60% 100% 1000% 2000%
624 limit Reflection Reflection Reflection Reflection
1% 92 144 4370* 15927*
10% 925 1445 43700* 159272*
20% 1849 2889 87401* 318544*
30% 2774 4334* 131101* 477816*
40% 3698 5779* 174802* 637088*
50% 4623* 7223* 218502* 796360*
60% 5547* 8668* 262203* 955632*
70% 6472* 10113* 305903* 1114904*
80% 7397* 11557* 349604* 1274176*
90% 8321* 13002* 393304* 1433448*
100% 9246* 14446* 437005* 1592720*

This table shows RF power density at 3″ distance at surface of meter.

*Exceeds 4000 uW/cm2 at 3″ from antenna radiation center at face of meter.

Table 16: FCC 3 Viol 1.4

One Meter Table A1 Table A2 Table A3 Table A4
Duty Cycle 60% 100% 1000% 2000%
Reflection Reflection Reflection Reflection
1% 19 29 890 3245
10% 188 294 8904* 32453*
20% 377 589 17809* 64906*
30% 565 883 26713* 97360*
40% 754 1177 35618* 129813*
50% 942 1472 44522* 162266*
60% 1130 1766 53426* 194719*
70% 1319 2061 62331* 227172*
80% 1507 2355 71235* 259626*
90% 1696 2649 80140* 292079*
100% 1884 2944 89044* 324532*
Four Meter Table A5 Table A6 Table A7 Table A8
Duty Cycle 60% 100% 1000% 2000%
Reflection Reflection Reflection Reflection
1% 75 118 3562 12981*
10% 754 1177 35618* 129813*
20% 1507 2355 71235* 259626*
30% 2261 3532 106853* 389438*
40% 3014 4710* 142470* 519251*
50% 3768 5887* 178088* 649064*
60% 4521* 7065* 213705* 778877*
70% 5275* 8242* 249323* 908690*
80% 6029* 9420* 284941* 1038503*
90% 6782* 10597* 320558* 1168315*
100% 7536* 11774* 356176* 1298128*

This table shows RF power density at 3″ distance at surface of meter

*Exceeds 4000 uW/cm2 at 3 from antenna radiation center at face of meter.

Table 15: Kitchen FCC 576 629

One Collector Table A41 Table A42 Table A43 Table A44
Duty Cycle 60% 100% 1000% 2000%
571 limit Reflection Reflection Reflection Reflection
1% 0.6 uW/cm2 1 28.8 105
5% 3.1 4.8 144 525
10% 6.1 9.5 288 1049*
20% 12.2 19 576* 2098*
30% 18.3 28.6 864* 3148*
40% 24.4 38.1 1152* 4197*
50% 30.5 47.6 1439* 5246*
60% 36.5 57.1 1727* 6295*
70% 42.6 66.6 2015* 7344*
80% 48.7 75.1 2303* 8393*
90% 54.8 85.7 2591* 9243*
100% 60.9 95.2 2879* 10492*
One Collector +3 Meters** Table A45 Table A46 Table A47 Table A48
Duty Cycle 60% 100% 1000% 2000%
624 limit Reflection Reflection Reflection Reflection
1% 0.9 uW/cm2 1.5 45 162
5% 4.7 7.4 223 811*
10% 9.4 14.7 445 1622*
20% 18.8 29.4 890* 3245*
30% 28.3 44.2 1336* 4867*
40% 37.7 58.9 1781* 6490*
50% 47.1 73.6 2226* 8112*
60% 56.5 88.3 2671* 9734*
70% 65.9 103 3116* 11357*
80% 75.4 118 3561* 12979*
90% 84.8 132 4006* 14602*
100% 94.2 147 4452* 16224*

This table shows RF power density readings at 28″ in the kitchen work space.

*Exceeds 571/624 uW/cm2 FCC Limit

Table 14: Kitchen FCC 655

One Meter Table A33 Table A34 TableA35 Table A36
Duty Cycle 60% 100% 1000% 2000%
Reflection Reflection Reflection Reflection
1% 0.2 0.3 10.2 37.3
5% 1.1 1.7 51.1 186
10% 2.2 3.4 102 373
20% 4.3 6.8 204 745*
30% 6.5 10.1 307 1118*
40% 8.7 13.5 409 1490*
50% 10.8 16.9 511 1863*
60% 13 20.3 613 2235*
70% 15.1 23.7 716* 2608*
80% 17.3 27 818* 2980*
90% 19.5 30.4 920* 3353*
100% 21.6 33.8 1022* 3726*
Four Meter Table A37 Table A38 Table A39 Table A40
Duty Cycle 60% 100% 1000% 2000%
Reflection* Reflection Reflection Reflection
1% 0.6 0.9 26 94.6
5% 2.8 4.3 129 473
10% 5.5 8.6 260 946*
20% 11 17.2 519 1892*
30% 16.5 25.7 779* 2837*
40% 22 34.3 1038* 3783*
50% 27.5 42.9 1298* 4729*
60% 32.9 51.5 1557* 5675*
70% 38.4 60.1 1817* 6621*
80% 43.9 68.6 2076* 7566*
90% 49.4 77.2 2336* 8512*
100% 54.9 85.8 2595* 9458*

This table shows RF power density readings at 28″ in the kitchen work space.

*Exceeds 655 uW/cm2 FCC Limit

Table 13: Nursery FCC 576 629

One Collector Table A25 TableA26 Table A27 Table A28
Duty Cycle 60% 100% 1000% 2000%
571 limit Reflection Reflection Reflection Reflection
1% 4.0 uW/cm2 6.2 187 680*
5% 19.7 30.8 933* 3399*
10% 39.5 61.7 1865* 6798*
20% 78.9 123 3730* 13596*
30% 118 185 5596* 20394*
40% 158 247 7461* 27192*
50% 197 308 9326* 33990*
60% 237 370 11191* 40788*
70% 276 432 13056* 47586*
80% 316 493 14922* 54384*
90% 355 555 16787* 61182*
100% 395 617* 18652* 67980*
One Collector +3 Meters* Table A29 Table A30 Table A31 Table A32
Duty Cycle 60% 100% 1000% 2000%
624 limit Reflection Reflection Reflection Reflection
1% 7.4 uW/cm2 11.5 348 1267*
5% 36.8 57.5 1738* 6334*
10% 73.5 115 3476* 12668*
20% 147 230 6952* 25337*
30% 221 345 10428* 38005*
40% 294 460 13904* 50674*
50% 368 575 17380* 63342*
60% 441 689* 20855* 76010*
70% 515 804* 24331* 88679*
80% 588 919* 27807* 101347*
90% 662 1034* 31283* 114015*
100% 735 1149* 34759* 126684*

This table shows RF power density FCC violations at 11″

*Exceeds either 571 or 624 uW/cm2 FCC Limit

Table 12: Nursery FCC 655

One Meter Table A17 Table A18 Table A19 Table A20
Duty Cycle 60% 100% 1000% 2000%
Reflection* Reflection Reflection Reflection
1% 1.4 2.2 66.2 241
5% 7 11 331 1227*
10% 14 21.9 662* 2414*
20% 28 43.8 1324* 4828*
30% 42 65.7 1986* 7242*
40% 56.1 87.6 2649* 9655*
50% 70.1 109 3312* 12069*
60% 84.1 131 3974* 14483*
70% 98.1 153 4636 16897*
80% 112 175 5299* 19311*
90% 126 197 5961* 21175*
100% 140 218 6623* 24139*
Four Meter Table A21 Table A22 Table A23 Tab;e A24
Duty Cycle 60% 100% 1000% 2000%
Reflection* Reflection Reflection Reflection
1% 4.9 7.5 227 828*
5% 24 37.6 1137* 4142*
10% 48.1 75.1 2273* 8284*
20% 96.2 150 4546* 16569*
30% 144 225 6819* 24853*
40% 192 301 9092* 33137*
50% 240 376 11365* 41421*
60% 289 451 13638* 49705*
70% 337 526 15911* 57990*
80% 385 601 18184* 66274*
90% 433 676 20457* 74558*
100% 481 751 22730* 82843*

This table shows RF power density FCC violations at 11″.

*Exceeds 655 uW/cm2 FCC TWA Safety Limit.

Table 6: Kitchen Data

One Collector Table A41 Table A42 Table A43 Table A44
Duty Cycle 60% 100% 1000% 2000%
Reflection Reflection Reflection* Reflection*
1% 0.6 uW/cm2 1 28.8 105
5% 3.1 4.8 144 525
10% 6.1 9.5 288 1049
20% 12.2 19 576 2098
30% 18.3 28.6 864 3148
40% 24.4 38.1 1152 4197
50% 30.5 47.6 1439 5246
60% 36.5 57.1 1727 6295
70% 42.6 66.6 2015 7344
80% 48.7 75.1 2303 8393
90% 54.8 85.7 2591 9243
100%*** 60.9 95.2 2879 10492
One Collector +3 Meters** Table A45 Table A46 Table A47 Table A48
60% 100% 1000% 2000%
Duty Cycle Reflection Reflection Reflection* Reflection*
1% 0.9 uW/cm2 1.5 45 162
5% 4.7 7.4 223 811
10% 9.4 14.7 445 1622
20% 18.8 29.4 890 3245
30% 28.3 44.2 1336 4867
40% 37.7 58.9 1781 6490
50% 47.1 73.6 2226 8112
60% 56.5 88.3 2671 9734
70% 65.9 103 3116 11357
80% 75.4 118 3561 12979
90% 84.8 132 4006 14602
100%*** 94.2 147 4452 16224

This table shows RF power density for readings at 28 in the kitchen work space.

*Note: 1000-2000% reflection based on Vermeeren et al, 2010; Christ et al, 2010; Hondou, 2002.

**More than 4 meters placed together do not appreciably increase the exposure to one reference point such as a crib or bed. However, multiple meters can increase the square footage of space similarly affected.

***Continuous exposure is required in calculations of time-weighted average radiofrequency exposure
for uncontrolled public access by FCC OET 65 (p. 15).

Table 5: Kitchen Data

One Meter Table A33 Table A34 Table A35 Table A36
Duty Cycle 60% 100% 1000% 2000%
Reflection Reflection Reflection* Reflection*
1% 0.2 0.3 10.2 37.3
5% 1.1 1.7 51.1 186
10% 2.2 3.4 102 373
20% 4.3 6.8 204 745
30% 6.5 10.1 307 1118
40% 8.7 13.5 409 1490
50% 10.8 16.9 511 1863
60% 13 20.3 613 2235
70% 15.1 23.7 716 2608
80% 17.3 27 818 2980
90% 19.5 30.4 920 3353
100%*** 21.6 33.8 1022 3726
Four Meters* Table A37 Table A38 Table A39 Table A40
Duty Cycle 60% 100% 1000% 2000%
Reflection* Reflection Reflection* Reflection*
1% 0.6 0.9 26 94.6
5% 2.8 4.3 129 473
10% 5.5 8.6 260 946
20% 11 17.2 519 1892
30% 16.5 25.7 779 2837
40% 22 34.3 1038 3783
50% 27.5 42.9 1298 4729
60% 32.9 51.5 1557 5675
70% 38.4 60.1 1817 6621
80% 43.9 68.6 2076 7566
90% 49.4 77.2 2336 8512
100%*** 54.9 85.8 2595 9458

This table shows RF power density for readings at 28 in the kitchen work space.

*Note: 1000-2000% reflection based on Vermeeren et al, 2010; Christ et al, 2010; Hondou, 2002.

**More than 4 meters placed together do not appreciably increase the exposure to one reference point such as a crib or bed. However, multiple meters can increase the square footage of space similarly affected.

***Continuous exposure is required in calculations of time-weighted average radiofrequency exposure for uncontrolled public access by FCC OET 65 (p. 15).

Table 4: Nursery Data

One Collector Table A25 Table A26 Table A27 Table A28
Duty Cycle 60% 100% 1000% 2000%
Reflection Reflection Reflection* Reflection*
1% 4.0 uW/cm2 6.2 187 680
5% 19.7 30.8 933 3399
10% 39.5 61.7 1865 6798
20% 78.9 123 3730 13596
30% 118 185 5596 20394
40% 158 247 7461 27192
50% 197 308 9326 33990
60% 237 370 11191 40788
70% 276 432 13056 47586
80% 316 493 14922 54384
90% 355 555 16787 61182
100%*** 395 617 18652 67980
One Collector + 3 Meters* Table A29 Table A30 Table A31 Table A32
60% 100% 1000% 2000%
Duty Cycle Reflection Reflection Reflection* Reflection*
1% 7.4 uW/cm2 11.5 348 1267
5% 36.8 57.5 1738 6334
10% 73.5 115 3476 12668
20% 147 230 6952 25337
30% 221 345 10428 38005
40% 294 460 13904 50674
50% 368 575 17380 63342
60% 441 689 20855 76010
70% 515 804 24331 88679
80% 588 919 27807 101347
90% 662 1034 31283 114015
100%*** 735 1149 34759 126684

This table shows RF power density for readings at 11 in the crib.

*Note: 1000-2000% reflection based on Vermeeren et al, 2010; Christ et al, 2010; Hondou, 2002.

**More than 4 meters placed together do not appreciably increase the exposure to one reference point such as a crib or bed. However, multiple meters can increase the square footage of space similarly affected.

***Continuous exposure is required in calculations of time-weighted average radiofrequency exposure for uncontrolled public access by FCC OET 65 (p. 15).

Table 3: Nursery Data

One Meter Table A17 Table A18 Table A19 Table A20
Duty Cycle 60% 100% 1000% 2000%
Reflection* Reflection Reflection* Reflection*
1% 1.4 2.2 66 241
5% 7 11 331 1227
10% 14 21.9 662 2414
20% 28 43.8 1324 4828
30% 42 65.7 1986 7242
40% 56.1 87.6 2649 9655
50% 70.1 109 3312 12069
60% 84.1 131 3974 14483
70% 98.1 153 4636 16897
80% 112 175 5299 19311
90% 126 197 5961 21175
100%*** 140 218 6623 24139
Four Meters* Table A21 Table A22 Table A23 Table A24
Duty Cycle 60% 100% 1000% 2000%
Reflection* Reflection Reflection* Reflection*
1% 4.9 7.5 227 828
5% 24 38 1137 4142
10% 48 75 2273 8284
20% 96 150 4546 16569
30% 144 225 6819 24853
40% 192 301 9092 33137
50% 240 376 11365 41421
60% 289 451 13638 49705
70% 337 526 15911 57990
80% 385 601 18184 66274
90% 433 676 20457 74558
100%*** 481 751 22730 82843

This table shows RF power density for readings at 11 in the crib.

*Note: 1000-2000% reflection based on Vermeeren et al, 2010; Christ et al, 2010; Hondou, 2002.

**More than 4 meters placed together do not appreciably increase the exposure to one reference point such as a crib or bed. However, multiple meters can increase the square footage of space similarly affected.

***Continuous exposure is required in calculations of time-weighted average radiofrequency exposure for uncontrolled public access by FCC OET 65 (p. 15).

Table 2: 6 Face 1C Data

One Collector Table A9 Table A10 Table A11 Table A12
Duty Cycle 60% 100% 1000% 2000%
Reflection Reflection Reflection* Reflection*
1% 6 uW/cm2 10 296 1078
10% 63 98 958 10780
20% 125 196 5916 21561
30% 188 293 8874 32341
40% 250 391 11832 43121
50% 313 489 14789 53902
60% 376 587 17747 64682
70% 438 685 20705 75462
80% 501 782 23663 86243
90% 563 880 26621 97023
100%*** 626 978 29579 107803
One C + 3 SM** Table A13 Table A14 Table A15 Table A16
Duty Cycle 60% 100% 1000% 2000%
Reflection Reflectio Reflection* Reflection*
1% 19 29 890 3242
10% 188 294 8895 32420
20% 376 588 17990 64839
30% 565 882 26686 97259
40% 753 1176 35581 129678
50% 941 1470 43700 162098
60% 1129 1764 53371 194517
70% 1317 2058 62266 226937
80% 1506 2352 71161 259356
90% 1694 2647 80056 291776
100%*** 1882 2941 88952 324195

This table shows RF power density for face reading a meter at 6 distance.

*Note: 1000-2000% reflection based on Vermeeren et al, 2010; Christ et al, 2010; Hondou, 2002.

**More than 4 meters placed together do not appreciably increase the exposure to one reference point such as a crib or bed. However, multiple meters can increase the square footage of space similarly affected.

***Continuous exposure is required in calculations of time-weighted average radiofrequency exposure for uncontrolled public access by FCC OET 65 (p. 15).

Table 1: 6 FACE 1.4 DATA

One Meter Table A1 Table A2 Table A3 Table A4
Duty Cycle 60% 100% 1000% 2000%
Reflection Reflection Reflection* Reflection*
1% 2.1 uW/cm2 3.3 99 361
10% 21 33 989 3606
20% 42 65 1979 7212
30% 63 98 2968 10818
40% 83 131 3958 14424
50% 105 164 4947 18030
60% 105 196 5936 21636
70% 147 229 6926 25241
80% 168 262 7915 28847
90% 188 294 8904 32453
100%*** 209 327 9894 36059
Four Meters** Table A5 Table A6 Table A7 Table A8
Duty Cycle 60% 100% 1000% 2000%
Reflection* Reflection Reflection* Reflection*
15 uW/cm2 24 712 2596
10% 151 236 7124 25963
20% 301 471 14247 51925
30% 452 707 21371 77888
40% 603 942 28494 103850
50% 754 1177 35618 129813
60% 904 1413 42741 155775
70% 1055 1648 49865 181738
80% 1206 1884 56988 207701
90% 1356 2119 64112 233663
100%*** 1507 2355 71235 259626

This table shows RF power density for face reading a meter at 6 distance.

*Note: 1000-2000% reflection based on Vermeeren et al, 2010; Christ et al, 2010; Hondou, 2002.

**More than 4 meters placed together do not appreciably increase the exposure to one reference point such as a crib or bed. However, multiple meters can increase the square footage of space similarly affected.

***Continuous exposure is required in calculations of time-weighted average radiofrequency exposure for uncontrolled public access by FCC OET 65 (p. 15).

Table 11: FCC Viol 6 Face 1C Data

One Collector Table A9 Table A10 Table A11 Table A12
Duty Cycle 60% 100% 1000% 2000%
571 limit Reflection Reflection Reflection Reflection
1% 6 uW/cm2 9 279 1015*
10% 59 92 2786* 10152*
20% 118 184 5571* 20305*
30% 177 276 8357* 30457*
40% 236 368 11142* 40610*
50% 295 460 13928* 50762*
60% 354 553* 16713* 60914*
70% 413 645* 19449* 71067*
80% 471 737* 22285* 81219*
90% 530 829* 25070* 91372*
100% 589* 921* 27856* 101524*
One C + 3 SM Table A13 Table A14 Table A15 Table A16
Duty Cycle 60% 100% 1000% 2000%
624 limit Reflection Reflection Reflection Reflection
1% 18 29 874* 3185
10% 185 289 8740* 31854*
20% 370 578 17480* 63709*
30% 555 867* 26220* 95563*
40% 740* 1156* 34960* 127418*
50% 925* 1445* 43700* 159272*
60% 1109* 1734* 52441* 191126*
70% 1294* 2023* 61181* 222981*
80% 1479* 2311* 69921* 254835*
90% 1664* 2600* 78661* 286690*
100% 1849* 2889* 87401* 318544*

This table shows RF power density for face reading a meter at 6 distance.

*Exceeds 571 or 624 uW/cm2 at 6 at the face.

Table 10: FCC 6 viol 1.4

One Meter Table A1 Table A2 Table A3 Table A4
Duty Cycle 60% 100% 1000% 2000%
Reflection Reflection Reflection Reflection
1% 2.1 uW/cm2 3.3 99 361
10% 21 33 989* 3606*
20% 42 65 1979* 7212*
30% 63 98 2968* 10818*
40% 83 131 3958* 14424*
50% 105 164 4947* 18030*
60% 105 196 5936* 21636*
70% 147 229 6926* 25241*
80% 168 262 7915* 28847*
90% 188 294 8904* 32453*
100% 209 327 9894* 36059*
Four Meters Table A5 Table A6 Table A7 Table A8
Duty Cycle 60% 100% 1000% 2000%
Reflection Reflection Reflection Reflection
15 uW/cm2 24 712* 2596*
10% 151 236 7124* 25963*
20% 301 471 14247* 51925*
30% 452 707* 21371* 77888*
40% 603 942* 28494* 103850*
50% 754* 1177* 35618* 129813*
60% 904* 1413* 42741* 155775*
70% 1055* 1648* 49865* 181738*
80% 1206* 1884* 56988* 207701*
90% 1356* 2119* 64112* 233663*
100% 1507* 2355* 71235* 259626*

This table shows RF power density for face reading a meter at 6″ distance.

*Exceeds 655 uW/cm2 at 6″ at the face.

Table 9: FCC Peak Power Distance

PEAK POWER LIMIT

(Distance at which 4000 uW/cm2*** FCC peak limit is exceeded in inches)

60% 100% 1000% 2000%
Reflection Reflection Reflection* Reflection*
One Smart Meter 2” 2.6” 14.2” 27”
Four Smart Meters 4.1” 5.2” 28.3” 54”
One Collector Meter 4” 4.5” 24” 46.7”
One Collector +3 SM 5.0” 6.3” 34.6” 66.1”

*Note: 1000-2000% reflection based on Vermeeren et al, 2010; Christ et al, 2010; Hondou, 2002.

**More than 4 meters placed together do not appreciably increase the exposure to one reference point, such as a crib or bed. However, multiple meters can increase the square footage of space similarly affected.

*** FCC OET 65 and ANSI/IEEE C95.1-1992, 1999 specify that 4000 uW/cm2 public safety limit be applied for frequencies between 300 MHz and 6 GHz (6000 MHz) for peak power exposure.

Table 8: Distance to FCC1C, 3 SM

DISTANCE AT WHICH FCC TWA SAFETY LIMIT IS EXCEEDED FOR COLLECTOR METER (in inches)

(FCC limit is 571 uW/cm2 or 624 uW/cm2 for collector+ 3 SM)

FCC Limit=571 uW/cm2 for collector meter

One Meter (1 collector) Table A9 Table A10 Table A11 Table A12
Duty Cycle 60% 100% 1000% 2000%
Reflection Reflection Reflection* Reflection*
1% 0.9” 1.2” 6.5” 12.3”
10% 3.0” 3.7” 20.4” 39.0”
20% 4.2” 5.2” 28.9” 55.1”
30% 5.1” 6.4” 35.3” 67.5”
40% 5.9” 7.4” 40.8” 77.9”
50% 6.6” 8.3” 45.6” 87.1”
60% 7.3” 9.1” 50.0” 95.4”
70% 7.9” 9.8” 54.0” 103”
80% 8.4” 10.5” 57.7” 110”
90% 8.9” 11.1” 61.2” 116”
100%*** 9.4” 11.7” 64.5” 123”

FCC Limit = 624 uW/cm2 for collector meter plus 3 smart meters

*Note: 1000-2000% reflection based on Vermeeren et al, 2010; Christ et al, 2010; Hondou, 2002.

**More than 4 meters placed together do not appreciably increase the exposure to one reference point, such as a crib or bed. However, multiple meters can increase the square footage of space similarly affected.

***Continuous exposure is required in calculations of time-weighted average radiofrequency exposure for uncontrolled public access by FCC OET 65 (p. 15)

One Collector** + 3 Smart Meters Table A13 Table A14 Table A15 Table A16
Duty Cycle 60% 100% 1000% 2000%
Reflection Reflection Reflection* Reflection*
1% 1.6” 2.1” 10.9” 21.3
10% 4.2” 5.6” 35.6” 68.1”
20% 6.7” 8.7” 50.4” 96.3”
30% 8.5” 10.8” 61.7” 118”
40% 9.9” 12.6” 71.3” 136”
50% 11.2” 14.2” 79.7” 152”
60% 12.4” 15.6” 87.4” 167”
70% 13.4” 16.9” 94.4” 180”
80% 14.4” 18.1” 101” 193”
90% 15.3” 19.2” 107” 204”
100%*** 16.1” 20.3” 113” 215”

Table 7: Distance to FCC 1.8 SM

DISTANCE AT WHICH FCC TWA SAFETY LIMIT IS EXCEEDED (in inches)

(FCC limit is 655 uW/cm2 in smart meters)

One Smart Meter Table A1 Table A2 Table A3 Table A4
Duty Cycle 60% 100% 1000% 2000%
Reflection Reflection Reflection* Reflection*
1% 0.5” 0.6” 3.5” 6.68”
10% 1.6” 2.0” 11.1” 21.1”
20% 2.3” 2.8” 15.6” 29.9”
30% 2.8” 3.5” 19.2” 36.6”
40% 3.2” 4.0” 22.1” 42.2”
50% 3.6” 4.5” 24.7” 47.3”
60% 3.9” 4.9” 27.1” 51.7”
70% 4.3” 5.3” 29.3” 55.9”
80% 4.6” 5.7” 31.3” 59.8”
90% 4.8” 6.0” 33.2” 63.4”
100%*** 5.1” 6.4” 35.0” 66.8”

*Note: 1000-2000% reflection based on Vermeeren et al, 2010; Christ et al, 2010; Hondou, 2002.

**More than 4 meters placed together do not appreciably increase the exposure to one reference point, such as a crib or bed. However, multiple meters can increase the square footage of space similarly affected.

***Continuous exposure is required in calculations of time-weighted average radiofrequency exposure for uncontrolled public access by FCC OET 65 (p. 15).

Four Meters** Table A5 Table A6 Table A7 Table A8
Duty Cycle 60% 100% 1000% 2000%
Reflection Reflection Reflection* Reflection*
1% 1.44″ 1.8″ 9.4″ 18.7″
10% 3.42″ 4.8″ 31.2″ 59.7”
20% 5.70″ 7.47″ 44.2″ 84.0”
30% 7.29″ 9.39″ 54.1″ 103.4”
40% 8.6″ 11.0″ 62.5″ 119.5”
50% 9.73″ 12.4″ 70″ 133.6”
60% 10.7″ 13.6″ 76.6″ 146.3”
70% 11.7″ 14.8″ 82.2″ 158.0”
80% 12″ 15.8″ 88.4″ 169.0”
90% 13″ 16.8″ 93.8″ 179.3”
100%*** 14″ 17.7″ 98.9″ 188.9″