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Radiofrequency fields associated with SMART Meters were calculated following the methodology described here. Prediction methods specified in Federal Communications Commission, Office of Engineering and Technology Bulletin 65 Edition 97-01, August 1997 were used in the calculations.1

Section 2 of FCC OET 65 provides methods to determine whether a given facility would be in compliance with guidelines for human exposure to RF radiation. We used equation (3)

S = P x G x Duty Cycle symbol = EIRP x Duty Cycle symbol = 1.64 x ERP x Duty Cycle symbol
4 x Duty Cycle symbol x R2 4 x Duty Cycle symbol x R2 4 x Duty Cycle symbol x R2


S = power density (in µW/cm2)

P = power input to the antenna (in W)

G = power gain of the antenna in the direction of interest relative to an isotropic radiator

Duty Cycle symbol = duty cycle of the transmitter (percentage of time that the transmitter actually transmits over time)

R = distance to the center of radiation of the antenna


ERP = 1.64 EIRP


EIRP = is equivalent (or effective) isotropically radiated power referenced to an isotropic radiator

ERP = is equivalent (or effective) radiated power referenced to a half-wave dipole radiator

Analysis input assumptions

  1. SMART Meters [SK9AMI-4] have two RF transmitters (antennas) and are the type of smart meters typically installed on most buildings. They contain two antennas that transmit RF signals (916 MHz LAN and 2405 MHz Zigbee). The antennas CAN transmit simultaneously, and thus the maximum RF exposure is determined by the summation of power densities (from the FCC Certification Exhibit titled RF Exposure Report for FCC ID: SK9AMI-4).
    Model SK9AMI-4 transmits on 915 MHz is designated as LAN Antenna Gain for each model.

    • Transmitter Power Output (TPO) used is as shown on the grant issued by the Telecommunications Certification Body (TCB).
    • Antenna gain in dBi (decibels compared to an isotropic radiator) used comes from the ACS Certification Exhibit.
  2. Collector Meters [SK9AMI-2A] have three RF transmitters (antennas) and are installed where the utility needs them to relay RF signals from surrounding smart meters in a neighborhood. Collector meters contain a third antenna (GSM 850 MHz, 915 MHz LAN and 2405 MHz Zigbee). Collector meters can be placed on any building where a collector meter is needed to relay signals from the surrounding area. Estimates of the number of collector meters varies between one per 500 to one per 5000 smart meters. Collector meters will thus ‘piggyback’ the RF signals of hundreds or thousands of smart meters through the one collector meter. In a collector meter, only two of the three antennas can transmit simultaneously (the 915 MHz LAN and the GSM 850 MHz (from the FCC Certification Exhibit titled RF Exposure Report for FCC ID: SK9AMI-2A).
  3. The Cell Relay transmitting at 2480 MHz is not on most meters and not considered in this analysis.
    • Transmitter Power Output (TPO) used is as shown on the grant issued by the Telecommunications Certification Body (TCB).
    • Antenna gain in dBi (decibels compared to an isotropic radiator) used comes from the ACS Certification Exhibit.

ERP (Effective Radiated Power) used in the computer modeling here is calculated using the TPO and antenna gain established for each model

Reflection Factor

This equation is modified with the inclusion of a ground reflection factor as recommended by the FCC. The ground reflection factor accounts for possible ground reflections that could enhance the resultant power density. A 60% (0.6) enhancement would result in a 1.6 (1 + 0.6) increase of the field strength or a 2.56 = (1.6)2 increase in the power density. Similar increases for larger enhancements of the field strength are calculated by the square of the original field plus the enhancement percentage. 2.3.4

Reflection Factors:

60% = (1 + 0.6)2 = 2.56 times

100% = (1 + 1)2 = 4 times

1000% = (1 + 10)2 = 121 times

2000% = (1 + 20)2 = 441 times

Duty Cycle

How frequently SMART Meters can and will emit RF signals from each of the antennas within the meters is uncertain, and subject to wide variations in estimation. For this reason, and because FCC OET 65 mandates a 100% duty cycle (continuous exposure where the public cannot be excluded) the report gives RF predictions for all cases from 1% to 100% duty cycle at 10% intervals. The reader can see the variation in RF emissions predicted at various distances from the meter (or bank of meters) using this report at all duty cycles. Thus, for purposes of this report, duty cycles have been estimated from infrequent to continuous. Duty cycles for SMART Meters were calculated at:

Duty cycle :

1% 50%

5% 60%

10% 70%

20% 80%

30% 90%

40% 100%

Continuous Exposure

FCC Bulletin OET 65 and the ANSI/IEEE C95.1-1992, 1999 requires that continuous exposure be calculated for situations where there is uncontrolled public access. Continuous exposure in this case means reading the tables at 100% duty cycle.

Another feature of the exposure guidelines is that exposures, in terms of power density, E2 or H2, may be averaged over certain periods of time with the average not to exceed the limit for continuous exposure.11
As shown in Table 1 of Appendix A, the averaging time for occupational/controlled exposures is 6 minutes, while the averaging time for general population/uncontrolled exposures is 30 minutes. It is important to note that for general population/uncontrolled exposures it is often not possible to control exposures to the extent that averaging times can be applied. In those situations, it is often necessary to assume continuous exposure.” (FCC OET 65, Page 15)

Calculation Distances in Tables (3-inch increments)

Calculations were performed in 3-inch (.25 foot) increments from the antenna center of radiation. Calculations have been taken out to a distance of 96 feet from the antenna center for radiation for each of the conditions above. The antenna used for the various links in a SMART Meter is assumed to be at the center of the SMART Meter from front to back – approximately 3 inches from the outer surface of the meter.

Calculations have also been made for a typical nursery and kitchen. In the nursery it has been assumed that the baby in his or her crib that is located next to the wall where the electric SMART Meters are mounted. The closest part of the baby’s body can be as close as 11 inches* from the meter antenna. In the kitchen it has been assumed that a person is standing at the counter along the wall where the electric SMART Meters are mounted. In that case the closest part of the adult’s body can be located as close to the meter antenna as 28 inches.

The exposure limits are variable according to the frequency (in megahertz). Table 1, Appendix A show exposure limits for occupational (Part A) and uncontrolled public (Part B) access to radiofrequency radiation such as is emitted from AM, FM, television and wireless sources.

Conditions Influencing Radiofrequency Radiation Level Safety

The location of the meter in relation to occupied space, or outside areas of private property such as driveways, walk-ways, gardens, patios, outdoor play areas for children, pet shelters and runs, and many typical configurations can place people in very close proximity to smart meter wireless emissions. In many instances, smart meters may be within inches or a few feet of occupied space or space that is used by occupants for daily activities.

Factors that influence how high RF exposures may be include, but are not limited to where the meter is installed in relation to occupied space, how often the meters are emitting RF pulses (duty cycle), and what reflective surfaces may be present that can greatly intensify RF levels or create ‘RF hot spots’ within rooms, and so on. In addition, there may be multiple wireless meters installed on some multi-family residential buildings, so that a single unit could have 20 or more electric meters in close proximity to each other, and to occupants inside that unit. Finally, some meters will have higher RF emissions, because – as collector units – their purpose is to collect and resend the RF signals from many other meters to the utility. A collector meter is estimated to be required for every 500 to 5000 buildings. Each collector meter contains three, rather than two transmitting antennas. This means higher RF levels will occur on and inside buildings with a collector meter, and significantly more frequent RF transmissions can be expected. At present, there is no way to predict whose property will be used for installation of collector meters.

People who are visually reading the wireless meters ‘by sight’ or are visually inspecting and/or reading the digital information on the faceplate may have their eyes and faces only inches from the antennas.

Current standards for peak power limit do not have limits to protect the eyes and testes from instantaneous peak power from smart meter exposures, yet relevant documents identify how much more vulnerable these organs are, and the need for such safety limits to protect the eyes and testes.

No Baseline RF Assessment

Smart meter and collector meter installation are taking place in an information vacuum. FCC compliance testing takes place in an environment free of other sources of RF, quite unlike typical urban and some rural environments. There is no assessment of baseline RF conditions already present (from AM, FM, television and wireless communication facilities (cell towers), emergency and dispatch wireless, ham radio and other involuntary RF sources. Countless properties already have elevated RF exposures from sources outside their own control.

Consumers may also have already increased their exposures to radiofrequency radiation in the home through the voluntary use of wireless devices (cell and cordless phones), PDAs like BlackBerry and iPhones, wireless routers for wireless internet access, wireless home security systems, wireless baby surveillance (baby monitors), and other emerging wireless applications.

Neither the FCC, the CPUC, the utility nor the consumer know what portion of the allowable public safety limit is already being used up or pre-empted by RF from other sources already present in the particular location a smart meter may be installed and operated.

Consumers, for whatever personal reason, choice or necessity who have already eliminated all possible wireless exposures from their property and lives, may now face excessively high RF exposures in their homes from smart meters. This may force limitations on use of their otherwise occupied space, depending on how the meter is located, building materials in the structure, and how it is furnished.

* Flush-mounted main electric panels that house smart meters are commonly installed; placing smart meters 5” 6” closer to occupied space than box-mounted main electric panels that sit outward on exterior building walls. Assumptions on spacing are made for flush-mounted panels.