COMPLETED BOARD ORDER"�|E�2�38
Before the Board of Supervisors in and for the
County of Monterey, State of California
Accept a written report from Dr. Hugh
Stallworth, Director of Public Health/Health
Officer regarding Smart Meters Referral #
2010.20)
Upon motion of Supervisor Parker seconded by Supervisor Armenta, and carried by those
members present, effective January 11, 2011, the Board hereby;
Accept a written report from Dr. Hugh Stallworth, Director of Public Health/Health
Officer regarding Smart Meters Referral # 2010.20).
CONTINUED TO A FUTURE DATE this 11th day of January 2011, by the following
vote, to wit:
AYES: Supervisors Armenta, Calcagno, Salinas, Parker, Potter
NOES: None
ABSENT: None
I, Gail T. Borkowski, Clerk of the Board of Supervisors of the County of Monterey, State of California,
hereby certify that the foregoing is a true copy of an original order of said Board of Supervisors duly made
and entered in the minutes thereof of Minute Book 75 for the meeting on January 11, 2011.
Dated: January 21, 2011 Gail T. Borkowski, Clerk of the Board of Supervisors
County of Monterey, State of California
Deputy
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PUBLIC COMMENT�T��"�|E����Page 1 of 1
From: S. Jack Lewtschuk blacklion@royal.net]
Sent: Tuesday, January 11, 2011 9:55 AM
To: 112-Clerk of the Board Everyone
Subject: New meters
PG&E arrived at my home to install the new meters unannounced.
Apparently they could not get to the wall due to vegetation.
Instead of knocking at my door I was at home all day) and tell me
that they are just outside and have a problem, they left.
A few days later, I received a call from PG&E.
I think that courtesy would dictate that a homeowner needs to be
notified when any work is to be done on his/her property,
Also, I am not yet persuaded that these meters are safe and/or
accurate.
S. Jack Lewtschuk
blacklion@royal.net
1/11/2011
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PUBLIC COMMENT�T��"�|E����Page 1 of 4
Boyd, Arlene P. 759-6642
From: Chappell, Lori A. on behalf of 100-District 4 831) 883-7570
Sent: Tuesday, January 11, 2011 1:30 PM
To: 112-Clerk of the Board Everyone
Subject: FW: Smart Meter report, #38 consent agenda
Follow Up Flag: Follow up
Flag Status: Green
Attachments: Marin Ordinance 3552.pdf; CPUC m EMFSN rehearing apppdf; Cindy Sage declaration
Jan 4, 2011.doc; Cindy Sage Smart Meter Report Jan, 2011.doc; Structure Group-
Bakersfield article 4-10.doc; Structure Group Report excerpt wo PG.doc
Sincerely,
Lori
HGppq New Years.....
Office Manager I Supervisor Jane Parker
County of Monterey I Fourth District- Main Coastal Office
26161st Avenue, Marina CA 93933 I 831) 883-7571 phone
chappelllaPeo.monterev ca.us I www.janeparker.org
be green. think before you print.
Original Message-----
From: nbeety@netzero.net mailto:nbeety@netzero.net]
Sent: Monday, January 10, 2011 9:11 PM
To: 100-District 1 831) 647-7991; 100-District 2 831) 755-5022; 100-District 3 831) 385-8333; 100-District 4
831) 883-7570; 100-District 5 831) 647-7755
Cc: nbeety@netzero.net
Subject: Smart Meter report, #38 consent agenda
January 10, 2011
Re: Consent Agenda Item #38: Health Department Report on PG&E Smart Meters
To the Monterey County Board of Supervisors:
Last Tuesday, Marin County Board of Supervisors passed an urgency ordinance halting the installation
of Smart Meters and infrastructure in the county. The ordinance is attached.
Tomorrow, the Santa Cruz Board of Supervisors will vote on an urgency ordinance, introduced by two
supervisors, which renews and strengthens the moratorium on Smart Meters and infrastructure they had
in place until Dec. 31. Also tomorrow, Lake County Board of Supervisors will be discussing a request
for a moratorium on Smart Meters. San Luis Obispo County will be taking up this issue at a future
meeting; a supervisor at the last meeting stated that his PG&E bill doubled after a Smart Meter was
installed.
I request that you reject the Health Department report on Smart Meters.
1/11/2011
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PUBLIC COMMENT�T��"�|E����Page 2 of 4
Since June, I have presented the Monterey County Board of Supervisors and the Health Department
with substantial and ongoing information and documentation concerning the many problems with Smart
Meters, including but not limited to the RF safety issues.
However, after an almost 5 month official investigation, the conclusion of the Health Department
appears to bypass all this information in favor of information from PG&E.
I think there is some confusion. PG&E is a for-profit commercial entity. It is not a public agency in any
way. It sells products electricity and natural gas to the public.
In addition, PG&E is a company with a very checkered history on safety, honesty, and admission of
responsibility.
As I stated in a previous letter, the Division of Ratepayer Advocates called PG&E information regarding
safety evidence about RF emissions and the safety of Smart Meters weak", unreliable", disputed",
and inadequate". The DRA said: The Commission should... give serious consideration to
investigating the health concerns raised by EMF Safety) Network and other groups." I've attached the
application for rehearing filed by EMF Safety Network.
Regarding the Monterey County Health Department report:
These meters are one million microwatt meters, with a range that can exceed two miles, and Silver
Spring claims that their signal can go through mountains yet PG&E claims they can't be felt inside a
house). I have sent you and the Health Department charts showing just how potent tiny fractions of one
microwatt can be.
Furthermore, PG&E has not disclosed the normal strength of the peak power pulses emitted by its Smart
Meters. However, PG&E representatives have said, we all use the same meters, and Southern California
Edison has disclosed that the normal strength of the peak pulse is 155,600 microwatts. Cell phones do
not emit bursts of 155,600 microwatts, nor do they emit around the clock, 7 days a week. Furthermore,
PG&E's figures are time-averaged, not actual numbers, and are for one meter in isolation, not in a mesh
network relaying off each other or part of a bank of meters.
The FCC
has exposure guidelines voluntary; it does not have safety standards or limits,
aggressively promotes the industry it is entrusted with regulating,
has repeatedly been urged to revise guidelines because of their inadequacy, by agencies such
as the EPA, public advocacy groups, and the public, and
has guidelines that are far more lax than other countries; in some, these Smart Meters would
be illegal, even on the basis of Richard Tell's time-averaged figures.
However, the brand new report by Cindy Sage, which is attached, shows that Smart Meters can even
exceed FCC guidelines.
I have requested from the Health Department the list of scientists with whom they discussed Smart
Meters and a list of literature reviewed to come to their conclusion. What I have received so far is a
letter from Michael Herz, PG&E's EMF Program, with statements from the World Health Organization.
1/11/2011
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PUBLIC COMMENT�T��"�|E����Page 3 of 4
PG&E frequently cites the World Health Organization. I sent the Health Department evidence of World
Health Organization conflicts-of-interest due to industry involvement in creating their recommendations.
I would be happy to send you and them more information.
The World Health Organization
was chastised by the medical journal Lancet for routinely neglecting evidence, and
their EMF Task Force
o was funded in part by telecommunications contributions; contributions by the utility
companies, if any, and the total extent of industry contributions are unknown, because
they won't open the books,
o was chaired by an industry consultant, Michael Repacholi, and
o his assistant was an employee of the industry's Electric Power Research Institute. Her
name: Leeka Kheifets. There is an extensive history on her conflicts of interests working
for EPRI, ICNIRP another international advisory group), PG&E, and the CPUC during
which time she requested her financial records be sealed). She is also a professor at
UCLA.
o had consultations and assistance from industry in drafting and finalizing
recommendations for the public.
I requested that County Health Department staff attend the Commonwealth Club forum in November on
Health Effects of Electromagnetic Fields" with international scientists presenting data. Did anyone
from the county attend?
As regards the Structure Group report, there are serious questions about the Structure Group's
independence and the accuracy of the report. Attached is an article from the Bakersfield Californian, as
well as an excerpt from their report.
PG&E information" meetings to educate" and assure concerned citizens" are sales pitches; they are
not information from an independent public advocacy group. The information PG&E provides, either
through their information" meetings or in print, may be true or it may not be, and must be evaluated
carefully. As with anything for sale, it is a case of buyer beware."
Why are they so intent on rolling out the Smart Grid and Meters over vocal and growing opposition and
the substantial problems?
It appears that PG&E and other utility companies will make a great deal of money on other uses for their
Smart Meters and Smart Grid, including city-wide Wi-Fi. This is showing up in a myriad of newspaper
accounts across the country. Last weekend in Las Vegas was a summit at the Consumer Electronics
Show to discuss Smart Grid opportunities." These meters will not just be firing with energy data.
Electric and gas income will probably be incidental compared to the sums they will earn in leasing out
the network, rendering all their statistics about transmit times a complete fiction.
This is a huge gamble, because the public might catch on. PG&E is working faster and faster to stay
ahead of the growing uproar.
1/11/2011
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PUBLIC COMMENT�T��"�|E����Page 4 of 4
What did Watsonville, Fairfax, and Santa Cruz and Marin Counties do? They adopted ordinances
halting these meters and their infrastructure.
Again, I request that you reject this report from the Health Department. And I further request that you
agendize consideration of an urgency ordinance at the very earliest date possible that not only halts the
installation of Smart Meters and their infrastructure, but also deactivates already installed Smart Meters
and infrastructure.
Sincerely,
Nina Beety
277 Mar Vista Dr.
Monterey, CA 93940
nbeety@netzero.net
Attached:
Marin County Smart Meter ordinance
EMF Safety Network Application for Rehearing to the CPUC
Cindy Sage Declaration and Report charts at http://sagereports.com/smart-meter-rf/)
Bakersfield Californian article on Structure Group
Structure Group Report excerpt
1/11/2011
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PUBLIC COMMENT�T��"�|E����ORDINANCE NO. 3552
AN UNCODIFIED ORDINANCE OF THE BOARD OF SUPERVISORS OF THE COUNTY OF
MARIN ADOPTED AS AN URGENCY MEASURE IMPOSING A TEMPORARY
MORATORIUM ON THE INSTALLATION OF SMARTMETERS AND RELATED EQUIPMENT
IN, ALONG, ACROSS, UPON, UNDER AND OVER THE PUBLIC STREETS AND OTHER
PLACES WITHIN THE UNINCORPORATED AREA OF MARIN COUNTY
THE BOARD OF SUPERVISORS OF THE COUNTY OF MARIN FIND AS FOLLOWS:
WHEREAS, the County of Marin the County"), through its police powers granted by
Article XI of the California Constitution, retains broad discretion to legislate for public purposes
and for the general welfare, including but not limited to matters of public health, safety and
consumer protection; and
WHEREAS, the County of Marin has a franchise agreement with PG&E that has been
in effect since the early 1950's; and
WHEREAS, in addition, the County retains authority under Article XII, Section 8 of the
Constitution to grant franchises for public utilities, and pursuant to California Public Utilities
Code section 6203, may in such a franchise impose such other and additional terms and
conditions..., whether governmental or contractual in character, as in the judgment of the
legislative body are to the public interest;" and
WHEREAS, Public Utilities Code section 2902 reserves the County's right to supervise
and regulate public utilities in matters affecting the health, convenience and safety of the
general public, such as the use and repair of public streets by any public utility, the location of
the poles, wires, mains, or conduits of any public utility, on, under, or above any public streets,
and the speed of common carriers operating within the limits of the municipal corporation;" and
WHEREAS, Pacific Gas & Electric Company PG&E") is now installing SmartMeters
in Central and Northern California and is installing these meters within the County of Marin; and
WHEREAS, concerns about the impact and accuracy of SmartMeters have been
raised nationwide, leading the Maryland Public Service Commission to deny permission on June
21, 2010. for the deployment of SmartMeters in that state. The State of Hawaii Public Utility
Commission also recently declined to adopt a smart grid system in that state. The CPUC
recently had before it a petition from the City and County of San Francisco, and other
municipalities, seeking to delay the implementation of SmartMeters until the questions about
their accuracy can be evaluated; and
WHEREAS, major problems and deficiencies with SmartMeters in California have
been brought to the attention of the Board of Supervisors of the County of Marin, including
PG&E's confirmation that SmartMeters have provided incorrect readings costing ratepayers
untold thousands of dollars in overcharges and PG&E's records outlined risks" and issues"
including an ongoing inability to recover real-time data because of faulty hardware originating
with PG&E vendors; and
WHEREAS, the ebb and flow of gas and electricity into homes discloses detailed
information about private details of daily life. Energy usage data, measured moment by
moment, allows the reconstruction of a household's activities: when people wake up, when they
Ordinance No. 3552
Page 1 of 4
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PUBLIC COMMENT�T��"�|E����WHEREAS, this Board of Supervisors has sent letters to the President of the CPUC
on July 20, 2010 and again on October 26, 2010 asking that the CPUC suspend PG&E's
authority to deploy SmartMeters or related equipment in Marin County until certain reports now
in process have been completed and reviewed and considered, and certain other conditions
have been met; and
WHEREAS, there has been no response to either of these letters; and
WHEREAS, because the potential risks to the health, safety and welfare of County
residents are so great, the Board of Supervisors wishes to adopt a moratorium on the
installation of SmartMeters and related equipment within the unincorporated area of the County
of Marin. The moratorium period will allow the Council on Science and Technology and
legislative process. referenced above to be completed and for additional information to be
collected and analyzed regarding potential problems with SmartMeters; and
WHEREAS, there is a current and immediate threat to public health, safety and
welfare because, without this urgency ordinance, SmartMeters or supporting equipment will be
installed or constructed or modified in the County without PG&E's complying with the CPUC
process for consultation with the local jurisdiction, the County's Code requirements, and
subjecting residents of Marin County to the privacy, security, health, accuracy and consumer
fraud risks of the unproven SmartMeter technology; and
WHEREAS, the Board of Supervisors hereby finds that it can be seen with certainty
that there is no possibility that the adoption and implementation of this Ordinance may have a
significant effect on the environment. This Ordinance does not authorize construction or
installation of any facilities and, in fact, imposes greater restrictions on such construction and
installation in order to protect the public health, safety and general welfare. This Ordinance is
therefore exempt from the environmental review requirements of the California Environmental
Quality Act CEQA) pursuant to Section 15061(b)(3) of Title 14 of the California Code of
Regulations; and
WHEREAS, there is no feasible alternative to satisfactorily study the potential impact
identified above as well or better with a less burdensome or restrictive effect than the adoption
of this interim urgency moratorium ordinance; and
WHEREAS, based on the foregoing it is in the best interest of public health, safety and
welfare to allow adequate study of the impacts resulting from the SmartMeter technology;
therefore it is appropriate to adopt a temporary moratorium that would remain in effect from the
date of its adoption until December 31, 2011, unless your Board acts to repeal it prior to that
date.
NOW, THEREFORE, BE IT ORDAINED by the Board of Supervisors of the County of
Marin as follows:
SECTION I
Moratorium. From and after the effective date of this Ordinance, no SmartMeter may
be installed in or on any home, apartment, condominium or business of any type within the
unincorporated area of the County of Marin, and no equipment related to SmartMeters may be
installed in, on, under, or above any public street or public right of way within the unincorporated
area of the County of Marin.
Ordinance No, 3552
Page 3 of 4
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PUBLIC COMMENT�T��"�|E����BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
Application of EMF Safety Network for Modification
of D.06-07-027 and D.09-03-026.
Application 10-04-018
Filed April 6, 2010)
APPLICATION OF EMF SAFETY NETWORK
FOR REHEARING OF DECISION 10-12-001
January 5, 2011
Sandra Maurer, Founder
EMF Safety Network
PO Box 1016
Sebastopol CA 95473
Tel. 707) 824-0824
sandi@emfsafetynetwork.org
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PUBLIC COMMENT�T��"�|E�� ��A.10-04-018 EMF Safety Network
TABLE OF AUTHORITIES
California Constitution
Article 1, Declarations of Rights Section 1 9
Article 1, Declarations of Rights Section 4 10
Article XII, Section 6 6
Public Utilities Code
Section 451 4, 6, 7
Section 701 6
Section 761 4
Section 762 4
Section 768 4
Section 1001 7
Section 1002 6, 7
Section 1757 3
Health and Safety Code
Section 120365 10
Commission Orders
Investigation 91-01-012 6
D.95-11-017 156,7
D.06-01-042 8
Commission General Orders
General Order 159A, Rules Relating to the Construction of Commercial
Mobile Radio Service Facilities in California
2,
12
General Order 168, Rules Governing Telecommunications Consumer
Protection
2,
11
Commission Rules
Rule 16.1 1,3
Rule 16.4(b) 13
Federal Law
National Environmental Policy Act of 1969 7
Telegraphs, Telephones, and Radiotelegraphs,
47 U.S.C. 332 c)(7)(b)(iv) 10
iii
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PUBLIC COMMENT�T��"�|E��
��A.10-04-018 EMF Safety Network
APPLICATION OF EMF SAFETY NETWORK
FOR REHEARING OF DECISION 10-12-001
1. Introduction and Summary
On December 2, 2010, the Commission signed Decision D.) 10-12-001, which
dismissed the application of EMF Safety Network Network) for modification of
D.06-07-027 and D.09-03-026, in which the Commission approved installation of Smart
Meters by Pacific Gas and Electric Company PG&E). The Commission mailed
D.10-12-001 to parties of record on December 6, 2010.
Pursuant to Rule 16.1 of the Commission's Rules of Practice and Procedure',
Network submits this application for rehearing of D.10-12-001. The due date for
applications for rehearing is January 5, 2011. Network will file this pleading
electronically on the due date.
The Commission has an obligation to ensure safe delivery of gas and electric
service and has committed legal error by neglecting and deferring its utility regulation
duties to the Federal Communications Commission FCC). This Commission, not the
FCC, mandated Smart Meters in the California. The Commission previously
investigated the heath impacts of radio frequency radiation RF) emissions. In
D.95-11-017, the Commission recognized public perception of harm, warned that
financial interests should not trump health impacts, and ordered follow-up workshops on
the subject. The basis for these outcomes was the possibility that a public health
hazard could exist.
In 2006 the Commission upheld a mandate to carry out no and low cost
electromagnetic field EMF) reduction measures. However, the Commission failed to
follow its own precautionary mandate by allowing PG&E and other utilities throughout
California to deploy RF Smart Meters.
The Commission's decision to dismiss Network's application relies heavily on
1 Rule 16.1 provides that an application for rehearing shall be filed within 30 days after
the date the Commission mails the order or decision.
1
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PUBLIC COMMENT�T��"�|E��
��Radiation Emissions from Smart Meters to document radiofrequency radiation
RF) levels associated with wireless smart meters in various scenarios depicting
common ways in which they are installed and operated.
5. The Report includes computer modeling of the range of possible smart meter RF
levels that are occurring in the typical installation and operation of a single smart meter,
and also multiple meters in California.
6. FCC compliance violations are likely to occur under normal conditions of
installation and operation of smart meters and collector meters in California, because
the public has access to smart meters installed on their homes.
7. In addition to exceeding FCC public safety limits under some conditions of
installation and operation, smart meters can produce excessively elevated RF
exposures, depending on where they are installed. RF levels are predicted to be
substantially elevated within a few feet to within a few tens of feet from the meter(s).
9. RF levels associated with smart meters under some conditions of installation and
operation will produce RF power density levels that exceed those reported in some
scientific studies to result in adverse health impacts, including headache, sleep
disruption, restlessness, tremor, cognitive impairment, tinnitus, increased cancer risk,
and cardiac problems at distances less than 500 meters from cell antennas, or at levels
over 0.1 microwatts per centimeter squared. 1.2.3.4.5.6
10. 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.
11. People who are afforded special protection under the federal Americans with
Disabilities Act are not sufficiently acknowledged nor protected. People who have
medical and/or metal implants or other conditions rendering them vulnerable to health
risks at lower levels than FCC RF limits may be particularly at risk.
1 http://sagereports.com/smart-meter-rf/
2
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PUBLIC COMMENT�T��"�|E��
��A.10-04-018 EMF Safety Network
2. Background
In D.10-12-001 the Commission granted the motion of PG&E to dismiss the
application of the EMF Safety Network for modification of D.06-07-027 and D.09-03-
026. The Decision Summary states that RF emissions from Smart Meters are 1/6000 of
the Federal standard at 10 feet from a Smart Meter.2 In its discussion the Commission
deferred its responsibility to the FCC then concluded that it was not reasonable to
reopen a review of Smart Meters based on alleged heath impacts.'
In the application, Network alleged that the RF from Smart Meters poses serious
public health, safety and environmental impacts.' Network challenged PG&E's
inconsistent and unreliable claims. Network stated it did not ask for regulation of RF by
the Commission.5 Network asked for an independently prepared RF Emissions Study;
public hearings on RF health, environmental, and safety impacts; review of actual Smart
Meter program performance; authorization for customers to opt out of Smart Meter
installation; and an immediate moratorium on PG&E Smart Meters.' These requests
and allegations of harm are backed by substantial peer-reviewed science, anecdotal
evidence, and widespread community expressions of concern.
3. Standard of Review
Public Utilities Code Section 1757 provides that, when a court reviews the validity
of a Commission decision, it considers, among other things, whether the findings in the
decision of the commission are not supported by substantial evidence in light of the
whole record." Rule 16.1 of the Commission's Rules of Practice and Procedure directs
applicants for rehearing to set forth specifically the grounds on which the applicant
considers the order or decision of the Commission to be unlawful or erroneous."
2 D.10-12-001, p. 1.
3 D.10-12-001, pp. 9, 15.
4 D.10-12-001, p. 14, Finding of Fact 1.
5 D.10-12-001, p. 5.
6 Application, p. 2.
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��A.10-04-018 EMF Safety Network
4.2 The Commission Wrongly Defers to the FCC
The Commission commits legal error by deferring its responsibility for the
deployment of Smart Meters to the FCC. The Decision defers to the FCC, stating, The
Commission generally does not delve into technical matters which fall within the
expertise of another agency, in this case, the FCC.""
Commission President and Assigned Commissioner Michael Peevey clearly
makes the case for deferral to the FCC in his statements regarding dismissal of
Network's Application12. At the Commission's December 2 public meeting, Peevey
stated, I believe that relying on the FCC in this case is reasonable, prudent and fully
consistent with our responsibilities to provide safe and reliable electric service to
ratepayers. We're relying on the federal agency in this regard." Commissioner Peevey
concluded his statements by telling the audience at the hearing, You should take these
concerns to the FCC, it's the proper body."
Although the Conclusions of Law in D.10-1 2-001 13 only mention reasonableness
generally, Commissioner Peevey made it clear that deferring to the FCC was the
primary reason for dismissal.
The Commission, not the FCC, mandated RF Smart Meters in California. It is the
responsibility of the Commission to serve the public interest by protecting consumers
and ensuring the provision of safe, reliable utility service and infrastructure at
reasonable rates, with a commitment to environmental enhancement and a healthy
California economy."14
The Division of Ratepayers Advocates DRA) concurs with Network about
Commission responsibility, stating, The FCC's authority to regulate RF emissions does
not deprive this Commission of its authority under state law to ensure that the in-state
11
D10-12-001, p. 9, Section 4.3
CPUC meeting Archive video http://www.californiaadmin.com/cpuc.shtml
D.10-12-001, p. 15.
CPUC home page: httpi/www.cpuc.ca.gov/puc/
12
13
14
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PUBLIC COMMENT�T��"�|E����A.10-04-018 EMF Safety Network
safety. 18 CACD Commission Advisory and Compliance Division] shall hold informal
cellular EMF and RF radiation workshops as additional health information becomes
available and upon preparation of any updated EMF reports, and shall report the results
of such workshops to the Commission through the resolution process.19"2o
In D.95-11-017, Appendix A, Section C, Issues for Future Consideration,
Issue #3, Public Perception of the Problem, states in part, The economic
considerations of this issue are significant. CACD raises the equally, if not more,
important issue of health and safety of the public. Public Utilities Code Section 451
requires regulated utilities to furnish and maintain facilities as necessary to promote the
health and safety of its patrons, employees and the public. Furthermore, Section 1002
requires the Commission, in granting any certificate, to consider the potential effects of
the project on community values and on the environment. The Commission is clearly
responsible for ensuring that the utilities it regulates are providing service and facilities
that do not constitute a threat to the public or the environment. As mentioned earlier,
the current research on the matter has left many questions unanswered and therefore
difficult to conclude that a health and safety problem does or does not exist. Until
clearer answers emerge, the Commission should consider the possibilities that a health
hazard could exist and that careful monitoring as well as some interim measures would
18 PU Code Section 1002, a) The commission, as a basis for granting any certificate
pursuant to Section 1001 shall give consideration to the following factors: 1)
Community values.(2) Recreational and park areas.(3) Historical and aesthetic values.
4) Influence on environment, except that in the case of any line, plant, or system or
extension thereof located in another state which will be subject to environmental impact
review pursuant to the National Environmental Policy Act of 1969 Chapter 55
commencing with Section 4321) of Title 42 of the United States Code) or similar state
laws in the other state, the commission shall not consider influence on the environment
unless any emissions or discharges there from would have a significant influence on the
environment of this state."
19 D.95-11-017, Ordering Paragraph 2.
20 D.95-11-017 is not directly available on the Commission's web site. See 1995 Cal.
PUC LEXIS 842; 165 P.U.R.41h 403. The document can be found at the web address
in footnote 16 herein.
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PUBLIC COMMENT�T��"�|E����A.10-04-018 EMF Safety Network
Furthermore, the FCC Grants of Equipment Authorization, which govern the rules
upon which FCC compliance is based, warn that RF exposure compliance depends on
specific conditions. As stated in Network's reply comments to the proposed decision
that preceded D.10-12-001, Network further alleges that RF Smart Meters in the
manner deployed by PG&E violate one or more conditions for FCC compliance. 21 See
also attached Declaration of Sandi Maurer. The CPUC must ensure the utilities adhere
to the necessary FCC conditions, within those Grants of Authorization.
4.6 The Commission Decision to Mandate Smart Meters Violates State
and Local Laws
The mandatory installation of radiation-emitting Smart Meters violates basic
rights granted by the State of California, overburdens utility easements and violates
local laws. The California Constitution, Article 1, Declaration of Rights, Section 1 states,
All people are by nature free and independent and have inalienable rights. Among
these are enjoying and defending life and liberty, acquiring, possessing, and protecting
property, and pursuing and obtaining safety, happiness, and privacy." Mandatory
installation of Smart Meters infringes on people's rights to protect their property, life and
liberty. The radiation emitted by Smart Meters is an environmental toxin which infringes
on people's rights to obtain safety. Existing utility franchise agreements generally lack
specific provisions regarding RF emissions. PG&E's installation of Smart Meters and
associated infrastructure goes far beyond the intentions of utility easements
incorporated into most if not all franchise agreements. Furthermore, standard
homeowner's insurance policies explicitly exclude RF damage from coverage, putting
ratepayers at risk for hazards not contemplated in utility franchise agreements. PG&E's
RF system violates at least one local wireless ordinance. For example, a City of
Sebastopol wireless facility ordinance26 requires that minor antennas cannot be installed
within 10 feet of power lines, cannot be installed on wood structures, and are limited to
25 Reply Comments of EMF Safety Network on Proposed Decision of ALJ Sullivan,"
November 22, 2010, pp. 1-3.
26 Chapter 17, General Provisions Relating to Telecommunications Facility and Minor
Antenna, Sections 17.100.010 A) through C).
9
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PUBLIC COMMENT�T��"�|E����A.10-04-018 EMF Safety Network
position that Smart Meters are mobile services facilities, then Network submits that the
Commission's General Order 168,29 which includes a Consumer Bill of Rights, should
apply to Smart Meters. The Consumer Bill of Rights states, The Commission declares
that all consumers who interact with telecommunications providers must be afforded
certain basic rights, and those rights shall be respected by the Commission-regulated
providers with whom they do business." The Consumer Bill of Rights includes the
following directives:
Disclosure: Consumers have a right to receive clear and complete information
about rates, terms and conditions for available products and services, and to be
charged only according to the rates, terms and conditions they have agreed to.
Choice: Consumers have a right to select their services and vendors, and to
have those choices respected by the industry.
Privacy: Consumers have a right to personal privacy, to have protection from
unauthorized use of their records and personal information, and to reject intrusive
communications and technology.
Public Participation and Enforcement: Consumers have a right to participate in
public policy proceedings, to be informed of their rights and what agencies
enforce those rights, and to have effective recourse if their rights are violated.
Accurate Bills and Redress: Consumers have a right to accurate and
understandable bills for products and services they authorize, and to fair, prompt
and courteous redress for problems they encounter.
Non-Discrimination: Every consumer has the right to be treated equally to all
other similarly-situated consumers, free of prejudice or disadvantage.
Safety: Consumers have a right to safety and security of their persons and
property."
29 General Order 168, Rules Governing Telecommunications Consumer Protection.
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PUBLIC COMMENT�T��"�|E����A.10-04-018 EMF Safety Network
5. Conclusion
The Commission should reopen its review of Smart Meters, and provide relief to
Network and other jurisdictions by ordering an immediate moratorium on the
deployment of RF Smart Meters. The Commission should convene public evidentiary
hearings on health, safety and environmental impacts, in order to provide ratepayers
and interested parties an opportunity to ensure that Commission policies are consistent
with delivery of safe gas and electric service.
Rule 16.4(b) requires that allegations of new facts must be supported by a
declaration or affidavit. Network has researched FCC regulations and has reviewed
PG&E's compliance with FCC conditions. The Declaration of Sandra Maurer asserts
that FCC Grants of Equipment Authorization, which govern the rules upon which FCC
compliance is based, warn that RF exposure compliance depends on specific
conditions, and that PG&E Smart Meters violate one or more conditions for FCC
compliance. The Declaration of Cynthia Sage summarizes a report titled Assessment
of Radiofrequency Microwave Radiation Emissions from Smart Meters," which
demonstrates that RF levels transmitted by publicly accessible PG&E Smart Meters can
violate FCC guidelines under normal conditions of installation and operation.
Dated January 5, 2011, at Sebastopol, California.
/s/
Sandra Maurer, Founder
EMF Safety Network
PO Box 1016
Sebastopol CA 95473
Tel. 707) 824-0824
sandi@emfsafetynetwork.org
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PUBLIC COMMENT�T��"�|E����A.10-04-018 EMF Safety Network
antenna(s) must not be co-located or operating in conjunction with any
other antenna or transmitter;
end-users and installers must be provided with antenna installation and
transmitter operating conditions to satisfy RF exposure compliance.
8. I doubt that several weeks of installer training qualifies PG&E installers as
professionals" and also doubts that Smart Meter installers are given accurate
information about RF operating conditions.
9. Many PG&E Smart Meters are installed within 20 cm of public access. In some
cases the meters are installed inside homes and businesses. In many situations Smart
Meters are easily accessible to the public.
10. PG&E Smart Meters are widely co-located in banks of multiple meters.
Co-location also occurs within Smart Meters because electric Smart Meters include at
least two internal RF antennas. One antenna is used for the mesh network system and
the other is for Home Area Network HAN) systems. Antennas are designed to work in
conjunction with HAN and RF appliances and with other Smart Meters in a mesh
network.
11. Antennas have separate Grants of Equipment Authorization, which suggests that
manufacturers have tested antennas in isolation and individually, and not in
combination, which is how the Smart Meter and the Smart Grid system were designed
to operate.
12. Network believes that end users" are utility customers. PG&E has not provided
end users with antenna installation and transmitter operating conditions to satisfy RF
exposure compliance. FCC conditions that specify that end users are to have no
manual instructions to remove or install the device confirm Network's belief that the end
user is the customer.
13. Research into other Smart Meter Grants of Equipment Authorizations indicates
there are similar violations in other utility districts in California.
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PUBLIC COMMENT�T��"�|E����A.10-04-018 EMF Safety Network
Declaration of Cynthia Sage, Sage Associates
I, Cynthia Sage, declare as follows:
1. My name is Cynthia Sage. I am the owner of Sage Associates, an environmental
consulting firm. My business address is 1396 Danielson Road, Montecito, California,
93108. I am providing this declaration in support of Application 10-04-018.
2. I have been a professional environmental consultant since 1972. I hold an M.A.
degree in Geology, and a B.A. in Biology Zoology) from the University of California,
Santa Barbara. I am a Senior Fellow, Department of Oncology, School of Health and
Medical Sciences, Orebro University, Orebro, Sweden 2008-2011).
3. I served as a member of the California Public Utilities Commission CPUC) EMF
Consensus Group 1990-1991), the Keystone Center Dialogue for Transmission Line
Siting a national group developing EMF Policy 1991-1992), and the International
Electric Transmission Perception Project. Between 1977 and 1981, I served as a
member of the California Board of Registration for Professional Engineers Department
of Consumer Affairs). I am a full member of the Bioelectromagnetics Society. I am the
co-editor of the Biolnitiative Report, and a founding member of the Biolnitiative Working
Group, an international scientific and public health research collaboration. I was a
Lecturer in the Environmental Studies Program, University of California, Santa Barbara
and a founding member of that program, and developed and taught classes in
environmental impact assessment from 1972 1981.
4. My professional involvement in this area includes constraint analysis,
environmental planning, and impact assessment on EMF and radiofrequency radiation
siting issues for more than 30 years. My company has provided professional consulting
services to city and county planners, private developers, state and federal agencies and
schools with respect to measurement and assessment of EMF as a part of land
planning and environmental constraints analysis since 1972. I have been an expert
witness who testified on EMF computer modeling, impacts on people and property, EMF
policy, public perception, visual impairment and land use issues, and have qualified
both in state and in federal court proceedings as an expert witness in this area.
1
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PUBLIC COMMENT�T��"�|E����A.10-04-018 EMF Safety Network
risks at lower levels than FCC RF limits may be particularly at risk.
12. 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.
13. 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 on a 24-hour basis.
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.
14. In summary, no positive assertion of safety can be made by the FCC, nor relied
upon by the CPUC, with respect to pulsed RF when exposures are chronic and occur in
the general population. 3.5.6 Indiscriminate exposure to environmentally ubiquitous
pulsed RF from the rollout of millions of new RF sources smart meters) will mean far
greater general population exposures, and potential health consequences.
Uncertainties about the existing RF environment how much RF exposure already
exists), what kind of interior reflective environments exist reflection factor), how interior
space is utilized near walls), and other characteristics of residents age, medical
condition, medical implants, relative health, reliance on critical care equipment that may
be subject to electronic interference, etc.) and unrestrained access to areas of property
where meter is located all argue for caution.
1. Khurana VG Hardell L Everaert J Bortkiewicz A Carlberg M Ahonen M, 2010.
Epidemiological Evidence for a Health Risk from Mobile Phone Base Stations. Int Journal of
Occupational Environmental Health 2010;16:263-267.
2. Kundi M Huffer HP Mobile phone base stations-Effects on wellbeing and health.
Pathophysiology 16 2009) 123-135.
3. Sage C. Carpenter DO. 2009. Public Health Implications of Wireless Technologies.
Pathophysiology 16 2009) 233-246.
4. Hardell L Sage C. Biological effect from electromagnetic field exposure and public exposure
standards. Biomedicine & Pharmacotherapy 2008;62:104-109. doi:10.1016/j.bipha.2007.12.004.
5. Biolnitiative Working Group, Cindy Sage and David O. Carpenter, Editors. Biolnitiative Report:
A Rationale for a Biologically-based Public Exposure Standard for Electromagnetic Fields ELF
and RF) at www.bioinitiative.org, August 31, 2007.
3
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PUBLIC COMMENT�T��"�|E����A.10-04-018 EMF Safety Network
VERIFICATION
I, Sandra Maurer, represent EMF Safety Network and am authorized to make this
verification on the organization's behalf. The statements in the foregoing document are
true to the best of my knowledge, except for those matters that are stated on
information and belief, and as to those matters I believe them to be true.
I declare under penalty of perjury that the foregoing is true and correct.
Dated January 5, 2011, at Sebastopol, California.
/s/
Sandra Maurer, Founder
EMF Safety Network
PO Box 1016
Sebastopol CA 95473
Tel. 707) 824-0824
sandi@emfsafetynetwork.org
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2010.20).-U012
PUBLIC COMMENT�T��"�|E����http://www.bakersfield.com/news/local/x2143248772/Utility-commission-rejects-
criticism-of-meter-test-firm
Bakersfield Californian
Utility commission rejects criticism of meter test firm
BY JOHN COX, Californian staff writer
jcox(a)bakersfield.com I Thursday, Apr 01 2010 08:34 PM
Last Updated Thursday, Apr 01 2010 08:34 PM
The state Public Utilities Commission on Thursday dismissed criticism that it created the
appearance of a conflict of interest when it awarded a SmartMeter investigation contract to a
consulting firm with business ties to Pacific Gas and Electric Co.
Commission staff examined different aspects of PG&E's relationship with the Houston-based
consulting firm, The Structure Group, and determined that they do not compromise the study's
integrity, commission spokeswoman Terrie Prosper wrote in an e-mail.
We are taking this evaluation very seriously and have the utmost confidence that Structure will
examine the facts in an unbiased and analytical manner," she wrote.
Structure again refused to answer questions Thursday about its ties to PG&E.
PG&E has acknowledged hiring the firm to do work unrelated to SmartMeters for seven years
ending in 2009. At least two senior workers at Structure previously worked for the utility's parent
company, PG&E Corp.
State Sen. Majority Leader Dean Florez D-Shafter) expressed disappointment Thursday that the
commission did not come forward sooner with its findings about the firm's relationship with
PG&E. But he stopped short of declaring a conflict of interest.
Florez also proposed a way to keep tabs on Structure's SmartMeter evaluation.
At the moment I am considering assembling a team of experts who could possibly provide the
legislature with a non-biased review of whatever Structure produces and how they operate," he
wrote in an e-mail.
But I hope that this seeming misstep with respect to transparency by the PUC and Structure isn't
an example of what is to be produced. We are all losing patience."
BIB]
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PUBLIC COMMENT�T��"�|E����According to Prosper's e-mail, when the commission is preparing to award a contract, it looks at
a range of relationships" between candidates for the job and the subjects they would be asked to
study.
In this case, she wrote, staff determined that the company has no ongoing contracts with PG&E,
and that the Structure principals who will work on this contract have not done work for PG&E in
the past.
Prosper added that the two former PG&E Corp. workers worked for the company more than 10
years ago, and that neither was employed by the utility directly.
I think it's perfectly justified to ask questions this is a very important issue," she wrote. But I
hope that any concern is alleviated by learning that we assessed potential conflicts of the
company and the principals working on the evaluation."
Fifteen firms submitted bids to conduct the evaluation of PG&E's SmartMeter system, which
uses remote electric meters some Kern customers blame for soaring power bills last summer. On
Tuesday, more than four months after the commission approved an expedited selection process,
Structure was announced the winner of a $1.4 million contract.
The contract calls for Structure to evaluate the meters' accuracy, look into customer complaints
about high bills and compare PG&E's meter rollout to the industry's best practices. The inquiry is
expected to take about four months.
Structure's website says the firm has worked with more than 120 utilities and energy companies
on various projects in the United States and Europe.
BIB]
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2010.20).-U012
PUBLIC COMMENT�T��"�|E����http://www.bakersfield.com/news/local/x2143248772/Utility-commission-rejects-
criticism-of-meter-test-firm
Bakersfield Californian
Utility commission rejects criticism of meter test firm
BY JOHN COX, Californian staff writer
icox(abakersfield.com I Thursday, Apr 01 2010 08:34 PM
Last Updated Thursday, Apr 01 2010 08:34 PM
The state Public Utilities Commission on Thursday dismissed criticism that it created the
appearance of a conflict of interest when it awarded a SmartMeter investigation contract to a
consulting firm with business ties to Pacific Gas and Electric Co.
Commission staff examined different aspects of PG&E's relationship with the Houston-based
consulting firm, The Structure Group, and determined that they do not compromise the study's
integrity, commission spokeswoman Terrie Prosper wrote in an e-mail.
We are taking this evaluation very seriously and have the utmost confidence that Structure will
examine the facts in an unbiased and analytical manner," she wrote.
Structure again refused to answer questions Thursday about its ties to PG&E.
PG&E has acknowledged hiring the firm to do work unrelated to SmartMeters for seven years
ending in 2009. At least two senior workers at Structure previously worked for the utility's parent
company, PG&E Corp.
State Sen. Majority Leader Dean Florez D-Shafter) expressed disappointment Thursday that the
commission did not come forward sooner with its findings about the firm's relationship with
PG&E. But he stopped short of declaring a conflict of interest.
Florez also proposed a way to keep tabs on Structure's SmartMeter evaluation.
At the moment I am considering assembling a team of experts who could possibly provide the
legislature with a non-biased review of whatever Structure produces and how they operate," he
wrote in an e-mail.
But I hope that this seeming misstep with respect to transparency by the PUC and Structure isn't
an example of what is to be produced. We are all losing patience."
BIB]
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PUBLIC COMMENT�T��"�|E����According to Prosper's e-mail, when the commission is preparing to award a contract, it looks at
a range of relationships" between candidates for the job and the subjects they would be asked to
study.
In this case, she wrote, staff determined that the company has no ongoing contracts with PG&E,
and that the Structure principals who will work on this contract have not done work for PG&E in
the past.
Prosper added that the two former PG&E Corp. workers worked for the company more than 10
years ago, and that neither was employed by the utility directly.
I think it's perfectly justified to ask questions this is a very important issue," she wrote. But I
hope that any concern is alleviated by learning that we assessed potential conflicts of the
company and the principals working on the evaluation."
Fifteen firms submitted bids to conduct the evaluation of PG&E's SmartMeter system, which
uses remote electric meters some Kern customers blame for soaring power bills last summer. On
Tuesday, more than four months after the commission approved an expedited selection process,
Structure was announced the winner of a $1.4 million contract.
The contract calls for Structure to evaluate the meters' accuracy, look into customer complaints
about high bills and compare PG&E's meter rollout to the industry's best practices. The inquiry is
expected to take about four months.
Structure's website says the firm has worked with more than 120 utilities and energy companies
on various projects in the United States and Europe.
BIB]
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PUBLIC COMMENT�T��"�|E����A.10-04-018 Declaration of Cynthia Sage, Sage Associates
Declaration of Cynthia Sage, Sage Associates
January 4, 2011
My name is Cynthia Sage. I am the owner of Sage Associates, an environmental consulting
firm. My business address is 1396 Danielson Road, Montecito, California, 93108. I am
providing a declaration in support of A. 10-04-018.
I have been a professional environmental consultant since 1972. I hold an M.A. degree in
Geology, and a B.A. in Biology Zoology) from the University of California, Santa Barbara. I
am a Senior Fellow, Department of Oncology, School of Health and Medical Sciences, Orebro
University, Orebro, Sweden 2008-2011).
I served as a member of the California Public Utilities Commission EMF Consensus Group
1990-1991), the Keystone Center Dialogue for Transmission Line Siting a national group
developing EMF Policy 1991-1992), and of the International Electric Transmission Perception
Project. Between 1977 and 1981, I served as a member of the California Board of Registration
for Professional Engineers Department of Consumer Affairs). I am a full member of the
Bioelectromagnetics Society. I am the co-editor of the Biolnitiative Report, and a founding
member of the Biolnitiative Working Group, an international scientific and public health
research collabortion. I was a Lecturer in the Environmental Studies Program, University of
California, Santa Barbara and a founding member of that program, and developed and taught
classes in environmental impact assessment from 1972 1981. My publications are attached.
My professional involvement in this area includes constraint analysis, environmental planning,
and impact assessment on EMF and radiofrequency radiation siting issues for more than 30
years. My company has provided professional consulting services to city and county planners,
private developers, state and federal agencies and schools with respect to measurement and
assessment of EMF as a part of land planning and environmental constraints analysis since 1972.
I have been an expert witness who testifies on EMF computer modeling, impacts on people and
property, EMF policy, public perception, visual impairment and land use issues, and have
qualified both in state and in federal court proceedings as an expert witness in this area.
1. Sage Associates has prepared the Assessment of Radiofrequency Microwave
1
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PUBLIC COMMENT�T��"�|E����Page 1 of 1
From: Mohammadi, Jayne F. x7708 on behalf of 100-District 5 831) 647-7755
Sent: Tuesday, January 11, 2011 8:56 AM
To: 112-Clerk of the Board Everyone
Subject: FW: Not-So-Smart) PG&E METERS
9)a tJ.n e l ll a rnAn i
Aide to Supervisor Dave Potter
County of Monterey, Board of Supervisors
831) 647-7755
831) 647-7708
The miracle is this the more we share, the more we have. Leonard Nimoy
From: liz mailto:nolancreates@yahoo.com]
Sent: Monday, January 10, 2011 10:43 PM
Subject: Not-So-Smart) PG&E METERS
SUPERVISORS: please do not approve the continued installation of Smart" Meters by PG&E as non-
dangerous to human health. There is so much scientific evidence that contradicts the completely
superficial report from Dr. Stallworth as to them being safe."
His report doesn't even address the RF SMOG effect of groups of smart meters which together increase
RF exposure far in excess of ONE meter's RF exposure! His report only cites the effect of one meter on
one residence. People are exposed to aggregate RF energy from all their neighbors meters---this is on top
of things we can choose to use like Wi-Fi and Cell Phones.
There is also ample evidence of these creating privacy invasion as the energy grid will next bring on
SMART appliances so that anyone who can access public records legally or not can find out what we
do inside our own homes related to what, when & how we consume energy.
And, accuracy of billing does not yet exist with use of Smart Meters.
I attended the Salinas PG&E information meeting and found the people unable to answer my
questions as to the effect of RF emission from groups of neighborhood meters mesh RF effect.) They
parroted the same superficial points that industry has put forth to force this risky and unnecessary
system on the public. The same PR prattle that Dr. Stallworth has bought into.
I am unable to attend tomorrow's meeting to voice this position in person.
Liz Nolan
1. 12-3 Nissen Road
Salinas,CA 93901
831-754-5645
1/11/2011
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PUBLIC COMMENT�T��"�|E�� ��From: marina meadows marinameadows@comcast.net]
Sent: Monday, January 10, 2011 8:16 PM
To: 112-Clerk of the Board Everyone
Subject: Smart Meters and the Sage Report
Importance: High
Attachments: Smart-Meter Report.docx
M
Smart Meter_Repo
rt.docx 89 KB...
Dear Supervisors,
We are very unhappy with Dr. Hugh Stallworth's recommendation that you accept Smart Meters
into Monterey County.
Please read and study the Sage Report we are attaching.
Many salient points are being missed; much disinformation is being disseminated by PG&E.
Too many issues are unaddressed.
Please take Item #38 off your agenda.
Please revisit this very grave concern of many Monterey County residents.
We need a town hall meeting to discuss.)
Something big is missing here and it is the TRUTH.
We do not want Smart Meters on our homes and businesses!
They are unsafe, dangerous, invasive, expensive and unhealthy!
hank you for thinking seriously about this issue and not going along with the Agenda 21
program.
Sincere Regards,
The Cecils
1
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PUBLIC COMMENT�T��"�|E�� ��SALE
Associates
ENVIRONMENTAL CONSULTANTS
Assessment of Radiofrequency
Microwave Radiation Emissions from
Smart Meters
Sage Associates
Santa Barbara, CA
USA
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PUBLIC COMMENT�T��"�|E�� ��January 1, 2011
TABLE OF CONTENTS
SUMMARY OF FINDINGS
INTRODUCTION
How Smart Meters Work
Mandate
Purpose of this Report
Conditions that Affect Radiofrequency Radiation Levels from Meters
Framing Questions
HOW THEY WORK
Mesh Network
Smart Meter(s) and collector meters
Power Transmitters
METHODOLOGY
APPLICABLE PUBLIC SAFETY LIMITS
FCC Bulletin OET 65 Guidelines Time-Averaging Limits)
ANSI/IEEE C95.1-1992, 1999 Peak Power Limits)
RESULTS, FINDINGS AND CONCLUSIONS
Tables 1-6 RF Levels at 6", 11" and 28" Face, Nursery, Kitchen)
Tables 7-17 FCC Violations of TWA and Peak Power)
Tables 18-31 Comparison of RF Levels to Health Studies)
Tables 32-33 Comparison to Biolnitiative Recommendation)
Tables Al- A 16 RF Power Density vs Distance Tables)
Tables A17-A32 Nursery at 11" Summary Tables)
Tables A33-A48 Kitchen at 28" Summary Tables)
BIB]
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PUBLIC COMMENT�T��"�|E�� ��APPENDIX A Tables Al A 16 RF Power Density vs. Distance Tables
Tables A17-A32 Nursery at 11" Summary Tables)
Tables A33-A48 Kitchen at 28" Summary Tables)
APPENDIX B Tables 1 33 Data Tables, FCC Violation Tables, Health
Comparisons
APPENDIX C Sensitivity of the Eye and Testes to RF Radiation
SUMMARY OF FINDINGS
This Report has been prepared to document radiofrequency radiation RF)
levels associated with wireless smart meters in various scenarios depicting
common ways in which they are installed and operated.
The Report includes computer modeling of the range of possible smart meter
RF levels that are occurring in the typical installation and operation of a
single smart meter, and also multiple meters in California. It includes
analysis of both two-antenna smart meters the typical installation) and of
three-antenna meters the collector meters that relay RF signals from another
500 to 5000 homes in the area).
RF levels from the various scenarios depicting normal installation and
operation, and possible FCC violations have been determined based on both
time-averaged and peak power limits Tables 1 14).
Potential violations of current FCC public safety standards for smart meters
and/or collector meters in the manner installed and operated in California are
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PUBLIC COMMENT�T��"�|E�� ��predicted in this Report, based on computer modeling Tables 10 17).
Tables 1 17 show power density data and possible conditions of violation
of the FCC public safety limits, and Tables 18 33 show comparisons to
health studies reporting adverse health impacts.
FCC compliance violations are likely to occur under normal conditions of
installation and operation of smart meters and collector meters in California.
Violations of FCC safety limits for uncontrolled public access are identified
at distances within 6" of the meter. Exposure to the face is possible at this
distance, in violation of the time-weighted average safety limits Tables 10-
11). FCC violations are predicted to occur at 60% reflection OET Equation
10 and 100% reflection OET Equation 6) factors*, both used in FCC OET
65 formulas for such calculations for time-weighted average limits. Peak
power limits are not violated at the 6" distance looking at the meter) but can
be at 3" from the meter, if it is touched.
This report has also assessed the potential for FCC violations based on two
examples of RF exposures in a typical residence. RF levels have been
calculated at distances of 11" to represent a nursery or bedroom with a crib
or bed against a wall opposite one or more meters); and at 28" to represent a
kitchen work space with one or more meters installed on the kitchen wall).
FCC compliance violations are identified at 11" in a nursery or bedroom
setting using Equation 10* of the FCC OET 65 regulations Tables 12-13).
These violations are predicted to occur where there are multiple smart
meters, or one collector meter, or one collector meter mounted together with
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PUBLIC COMMENT�T��"�|E��!��several smart meters.
FCC compliance violations are not predicted at 28" in the kitchen work
space for 60% or for 100% reflection calculations. Violations of FCC public
safety limits are predicted for higher reflection factors of 1000% and 2000%,
which are not a part of FCC OET 65 formulas, but are included here to allow
for situations where site-specific conditions highly reflective environments,
for example, galley-type kitchens with many highly reflective stainless steel
or other metallic surfaces) may be warranted.*
*FCC OET 65 Equation 10 assumes 60% reflection and Equation 6 assumes 100% reflection. RF levels
are also calculated in this report to account for some situations where interior environments have highly
reflective surfaces as might be found in a small kitchen with stainless steel or other metal counters,
appliances and furnishings. This report includes the FCC's reflection factors of 60% and 100%, and also
reflection factors of] 000% and 2000% that are more in line with those reported in Hondou, 2001; Hondou,
2006 and Vermeeren et al, 2010. The use of a 1000% reflection factor is still conservative in comparison
to Hondou, 2006. A 1000% reflection factor is 12% or 121 times as high) a factor for power density
compared to Hondou et al, 2006 prediction of 1000 times higher power densities due to reflection. A
2000% reflection factor is only 22% or 441 times) that of Hondou's finding that power density can be as
high as 2000 times higher.
In addition to exceeding FCC public safety limits under some conditions of
installation and operation, smart meters can produce excessively elevated RF
exposures, depending on where they are installed. With respect to absolute
RF exposure levels predicted for occupied space within dwellings, or outside
areas like patios, gardens and walk-ways, RF levels are predicted to be
substantially elevated within a few feet to within a few tens of feet from the
meter(s).
For example, one smart meter at 11" from occupied space produces
somewhere between 1.4 and 140 microwatts per centimeter squared
uW/cm2) depending on the duty cycle modeled Table 12). Since FCC
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PUBLIC COMMENT�T��"�|E��"��OET 65 specifies that continuous exposure be assumed where the public
cannot be excluded such as is applicable to one's home), this calculation
produces an RF level of 140 uW/cm2 at 11" using the FCCs lowest
reflection factor of 60%. Using the FCC's reflection factor of 100%, the
figures rise to 2.2 uW/cm2 218 uW/cm2, where the continuous exposure
calculation is 218 uW/cm2 Table 12). These are very significantly elevated
RF exposures in comparison to typical individual exposures in daily life.
Multiple smart meters in the nursery/bedroom example at 11" are predicted
to generate RF levels from about 5 to 481 uW/cm2 at the lowest 60%)
reflection factor; and 7.5 to 751 uW/cm2 using the FCCs 100% reflection
factor Table 13). Such levels are far above typical public exposures.
RF levels at 28" in the kitchen work space are also predicted to be
significantly elevated with one or more smart meters or a collector meter
alone or in combination with multiple smart meters). At 28" distance, RF
levels are predicted in the kitchen example to be as high as 21 uW/cm2 from
a single meter and as high as 54.5 uW/cm2 with multiple smart meters using
the lower of the FCCs reflection factor of 60% Table 14). Using the FCCs
higher reflection factor of 100%, the RF levels are predicted to be as high as
33.8 uW/cm2 for a single meter and as high as 85.8 uW/cm2 for multiple
smart meters Table 14). For a single collector meter, the range is 60.9 to
95.2 uW/cm2 at 60% and 100% reflection factors, respectively) from
Table 15).
Table 16 illustrates predicted violations of peak power limit 4000 uW/cm2)
at 3" from the surface of a meter. FCC violations of peak power limit are
predicted to occur for a single collector meter at both 60% and 100%
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PUBLIC COMMENT�T��"�|E��#��reflection factors. This situation might occur if someone touches a smart
meter or stands directly in front.
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 on a 24-hour basis. 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.
People who are afforded special protection under the federal Americans with
Disabilities Act are not sufficiently acknowledged nor protected. People
who have medical and/or metal implants or other conditions rendering them
vulnerable to health risks at lower levels than FCC RF limits may be
particularly at risk Tables 30-31). This is also likely to hold true for other
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PUBLIC COMMENT�T��"�|E��$��subgroups, like children and people who are ill or taking medications, or are
elderly, for they have different reactions to pulsed RF. Childrens' tissues
absorb RF differently and can absorb more RF than adults Christ et al,
2010; Wiart et al, 2008). The elderly and those on some medications respond
more acutely to some RF exposures.
Safety standards for peak exposure limits to radiofrequency have not been
developed to take into account the particular sensitivity of the eyes, testes
and other ball shaped organs. There are no peak power limits defined for
the eyes and testes, and it is not unreasonable to imagine situations where
either of these organs comes into close contact with smart meters and/or
collector meters, particularly where they are installed in multiples on walls
of multi-family dwellings that are accessible as common areas).
In summary, no positive assertion of safety can be made by the FCC, nor
relied upon by the CPUC, with respect to pulsed RF when exposures are
chronic and occur in the general population. Indiscriminate exposure to
environmentally ubiquitous pulsed RF from the rollout of millions of new
RF sources smart meters) will mean far greater general population
exposures, and potential health consequences. Uncertainties about the
existing RF environment how much RF exposure already exists), what kind
of interior reflective environments exist reflection factor), how interior
space is utilized near walls), and other characteristics of residents age,
medical condition, medical implants, relative health, reliance on critical care
equipment that may be subject to electronic interference, etc) and
unrestrained access to areas of property where meter is located all argue for
caution.
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PUBLIC COMMENT�T��"�|E��%��INTRODUCTION
How Smart Meters Work
This report is limited to a very simple overview of how smart meters work,
and the other parts of the communication system that are required for them
to transmit information on energy usage within a home or other building.
The reader can find more detailed information on smart meter and smart grid
technology from numerous sources available on the Internet.
Often called advanced metering infrastructure or AMI', smart meters are a
part of an overall system that includes a) a mesh network or series of
wireless antennas at the neighborhood level to collect and transmit wireless
information from all the smart meters in that area back to a utility.
The mesh network sometimes called a distributed antenna system) requires
wireless antennas to be located throughout neighborhoods in close proximity
to where smart meters will be placed. Often, a municipality will receive a
hundred or more individual applications for new cellular antenna service,
which is specifically to serve smart meter technology needs. The
communication network needed to serve smart meters is typically separate
from existing cellular and data transmission antennas cell tower antennas).
The mesh network or DAS) antennas are often utility-pole mounted. This
part of the system can spread hundreds of new wireless antennas throughout
neighborhoods.
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PUBLIC COMMENT�T��"�|E��&��Smart meters are a new type electrical meter that will measure your energy
usage, like the old ones do now. But, it will send the information back to the
utility by wireless signal radiofrequency/microwave radiation signal)
instead of having a utility meter reader come to the property and manually
do the monthly electric service reading. So, smart meters are replacements
for the older spinning dial' or analog electric meters. Smart meters are not
optional, and utilities are installing them even where occupants do not want
them.
In order for smart meters to monitor and control energy usage via this
wireless communication system, the consumer must be willing to install
power transmitters inside the home. This is the third part of the system and
involves placing power transmitters radiofrequency/microwave radiation
emitting devices) within the home on each appliance. A power transmitter is
required to measure the energy use of individual appliances e.g., washing
machines, clothes dryers, dishwashers, etc) and it will send information via
wireless radiofrequency signal back to the smart meter. Each power
transmitter handles a separate appliance. A typical kitchen and laundry may
have a dozen power transmitters in total. If power transmitters are not
installed by the homeowner, or otherwise mandated on consumers via
federal legislation requiring all new appliances to have power transmitters
built into them, then there may be little or no energy reporting nor energy
savings.
Smart meters could also be installed that would operate by wired, rather than
wireless means. Shielded cable, such as is available for cable modem wired
internet connection) could connect smart meters to utilities. However, it is
BIB]
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PUBLIC COMMENT�T��"�|E��'��not easy to see the solution to transmit signals from power transmitters
energy use for each appliance) back to the utility.
Collector meters are a special type of smart meter that can serve to collect
the radiofrequency/microwave radiation signals from many surrounding
buildings and send them back to the utility. Collector meters are intended to
collect and re-transmit radiofrequency information for somewhere between
500-5000 homes or buildings. They have three operating antennas
compared to two antennas in regular smart meters. Their radiofrequency
microwave emissions are higher and they send wireless signal much more
frequently. Collector meters can be place on a home or other building like
smart meters, and there is presently no way to know which a homeowner or
property owner might receive.
Mandate
The California Public Utilities Commission has authorized California's
investor-owned utilities including Pacific Gas & Electric, Southern
California Edison Company and San Diego Gas & Electric) to install more
than 10 million new wireless* smart meters in California, replacing existing
electric meters as part of the federal SmartGrid program.
The goal is to provide a new residential energy management tool. It is
intended to reduce energy consumption by providing computerized
information to customers about what their energy usage is and how they
might reduce it by running appliances during off-time' or lower load'
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PUBLIC COMMENT�T��"�|E��(��conditions. Presumably this will save utilities from having to build new
facilities for peak load demand. Utilities will install a new smart meter on
every building to which electrical service is provided now. In Southern
California, that is about 5 million smart meters in three years for a cost of
around $1.6 billion dollars. In northern California, Pacific Gas & Electric is
slated to install millions of meters at a cost of more than $2.2 billion dollars.
If consumers decide to join the program so that appliances can report
energy usage to the utility), they can be informed about using energy during
off-use or low-use periods, but only if consumers also agree to install
additional wireless power transmitters on appliances inside the home. Each
power transmitter is an additional source of pulsed RF that produces high
exposures at close range in occupied space within the home.
Proponents of smart meters say that when these meters are teamed
up with an in-home display that shows current energy usage, as well
as a communicating thermostat and software that harvest and analyze
that information, consumers can see how much consumption drives
cost and will consume less as a result. Utilities are spending
billions of dollars outfitting homes and businesses with the devices,
which wirelessly send information about electricity use to utility
billing departments and could help consumers control energy use.
Wall Street Journal, April 29, 2009.
The smart meter program is also a tool for load-shedding during heavy
electrical use periods by turning utility meters off remotely, and for reducing
the need for utility employees to read meter data in the field.
Purpose of this Report
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PUBLIC COMMENT�T��"�|E��)��This Report has been prepared to document radiofrequency radiation RF)
levels associated with wireless smart meters in various scenarios depicting
common ways in which they are installed and operated.
The Report includes computer modeling of the range of possible smart meter
RF levels that are occurring in the typical installation and operation of a
single smart meter, and also multiple meters in California. It includes
analysis of both two-antenna smart meters the typical installation) and of
three-antenna meters the collector meters that relay RF signals from another
500 to 5000 homes in the area).
RF levels from the various scenarios depicting normal installation and
operation, and possible FCC violations have been determined based on both
time-averaged and peak power limits Tables 1 14).
Potential violations of current FCC public safety standards for smart meters
and/or collector meters in the manner installed and operated in California are
illustrated in this Report, based on computer modeling Tables 10 17).
Tables which present data, possible conditions of violation of the FCC
public safety limits, and comparisons to health studies reporting adverse
health impacts are summarized Tables 18 33).
The next section describes methodology in detail, but generally this Report
provides computer modeling results for RF power density levels for these
scenarios, analysis of whether and under what conditions FCC public safety
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PUBLIC COMMENT�T��"�|E��*��limit violations may occur, and comparison of RF levels produced under
these scenarios to studies reporting adverse health impacts with chronic
exposure to low-intensity radiofrequency radiation at or below levels
produced by smart meters and collector meters in the manner installed and
operated in California.
1) Single typical' meter tables showing RF power density at
increasing distances in 0.25' 3") intervals outward for single
meter two-antenna meter). Effects of variable duty cycles from
1% to 90%) and various reflection factors 60%, 100%, 1000%
and 2000%) have been calculated.
2) Multiple typical' meters tables showing RF power density at
increasing distances as above.
3) Collector meter tables showing RF power density related to a
specialized collector meter which has three internal antennas one
for every 500 or 5000 homes) as above.
4) Collector meter a single collector meter installed with multiple
typical' two-antenna meters as above.
5) Tables are given to illustrate the distance to possible FCC
violations for time-weighted average and peak power limits in
inches).
6) Tables are given to document RF power density levels at various
key distances 11" to a crib in a bedroom; 28" to a kitchen work
area; and 6" for a person attempting to read the digital readout of
a smart meter, or inadvertently working around a meter.
7) Tables are given to compare RF power density levels with studies
reporting adverse health symptoms and effects and those levels
of RF associated with such health effects).
8) Tables are given to compare smart meter and collector meter RF
to Biolnitiative Report recommended limit in feet).
Framing Questions
In view of the rapid deployment of smart meters around the country, and the
relative lack of public information on their radiofrequency RF) emission
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PUBLIC COMMENT�T��"�|E��+��profiles and public exposures, there is a crucial need to provide independent
technical information.
There is very little solid information on which decision-makers and the
public can make informed decisions about whether they are an acceptable
new RF exposure, in combination with pre-existing RF exposures.
On-going Assessment of Radiofrequency Radiation Health Risks
The US NIEHS National Toxicology Program nominated radiofrequency
radiation for study as a carcinogen in 1999. Existing safety limits for
pulsed RF were termed not protective of public health" by the
Radiofrequency Interagency Working Group a federal interagency working
group including the FDA, FCC, OSHA, the EPA and others). Recently, the
NTP issued a statement indicating it will complete its review by 2014
National Toxicology Program, 2009). The NTP radiofrequency radiation
study results have been delayed for more than a decade since 1999 and very
little laboratory or epidemiological work has been completed. Thus, he
explosion of wireless technologies is producing radiofrequency radiation
exposures over massive populations before questions are answered by
federal studies about the carcinogenicity or toxicity of low-intensity RF such
as are produced by smart meters and other SmartGrid applications of
wireless. The World Health Organization and the International Agency for
Research on Cancer have not completed their studies of RF the IARC WHO
RF Health Monograph is not expected until at least 2011). In the United
States, the National Toxicology Program listed RF as a potential carcinogen
for study, and has not released any study results or findings a decade later.
BIB]
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PUBLIC COMMENT�T��"�|E��,��There are no current, relevant public safety standards for pulsed RF
involving chronic exposure of the public, nor of sensitive populations, nor of
people with metal and medical implants that can be affected both by
localized heating and by electromagnetic interference EMI) for medical
wireless implanted devices.
Considering that millions of smart meters are slated to be installed on
virtually every electrified building in America, the scope of the question is
large and highly personal. Every family home in the country, and every
school classroom every building with an electric meter is to have a new
wireless meter and thus subject to unpredictable levels of RF every day.
1) Have smart meters been tested and shown to comply with FCC
public safety limits limits for uncontrolled public access)?
2) Are these FCC public safety limits sufficiently protective of public
health and safety? This question is posed in light of the last thirty
years of international scientific investigation and public health
assessments documenting the existence of bioeffects and adverse
health effects at RF levels far below current FCC standards. The
FCC's standards have not been updated since 1992, and did not
anticipate nor protect against chronic exposures as opposed to acute
exposures) from low-intensity or non-thermal RF exposures,
particularly pulsed RF exposures.
3) What demonstration is there that wireless smart meters will comply
with existing FCC limits, as opposed to under strictly controlled
BIB]
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PUBLIC COMMENT�T��"�|E��-��conditions within government testing laboratories?
4) Has the FCC been able to certify that compliance is achievable under
real-life use conditions including, but not limited to:
In the case where there are both gas and electric meters on the
home located closely together.
In the case where there is a bank" of electric and gas meters,
on a multi-family residential building such as on a
condominium or apartment building wall. There are instances
of up to 20 or more meters located in close proximity to
occupied living space in the home,in the classroom or other
occupied public space.
In the case where there is a collector meter on a home that
serves the home plus another 500 to 5000 other residential units
in the area, vastly increasing the frequency of RF bursts.
In the case where there is one smart meter on the home but it
acts as a relay for other local neighborhood meters. What about
piggybacking' of other neighbors' meters through yours? How
can piggybacking be reasonably estimated and added onto the
above estimates?
What about the RF emissions from the power transmitters?
Power transmitters installed on appliances perhaps 10-15 of
BIB]
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PUBLIC COMMENT�T��"�|E��.��them per home) and each one is a radiofrequency radiation
transmitter.
How can the FCC certify a system that has an unknown number of
such transmitters per home, with no information on where they are
placed?
Where people with medical/metal implants are present?
Americans with Disabilities Act protects rights)
5) What assessment has been done to determine what pre-existing
conditions of RF exposure are already present. On what basis can
compliance for the family inside the residence be assured, when there
is no verification of what other RF sources exist on private property?
How is the problem of cumulative RF exposure properly assessed
wireless routers, wireless laptops, cell phones, PDAs, DECT or
other active-base cordless phone systems, home security systems,
baby monitors, contribution of AM, FM, television, nearby cell
towers, etc).
6) What is the cumulative RF emissions worst-case profile? Is this
estimate in compliance?
7) What study has been done for people with metal implants* who
require protection under Americans with Disabilities Act? What is
known about how metal implants can intensity RF, heat tissue and
result in adverse effects below RF levels allowed for the general
public. What is known about electromagnetic interference EMI)
from spurious RF sources in the environment RFID scanners, cell
BIB]
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PUBLIC COMMENT�T��"�|E��/��towers, security gates, wireless security systems, wireless
communication devices and routers, wireless smart meters, etc)
*Note: There are more than 20 million people in the US who need special protection against such
exposures that may endanger them. High peak power bursts of RF may disable electronics in some critical
care and medical implants. We already have reports of wireless devices disabling deep brain stimulators in
Parkinson's patients and there is published literature on malfunctions with critical care equipment.
PUBLIC SAFETY LIMITS FOR RADIOFREQUENCY RADIATION
The FCC adopted limits for Maximum Permissible Exposure MPE) are
generally based on recommended exposure guidelines published by the
National Council on Radiation Protection and Measurements NCRP) in
Biological Effects and Exposure Criteria for Radiofrequency
Electromagnetic Fields," NCRP, 1986).
In the United States, the Federal Communications Commission FCC)
enforces limits for both occupational exposures in the workplace) and for
public exposures. The allowable limits are variable, according to the
frequency transmitted. Only public safety limits for uncontrolled public
access are assessed in this report.
Maximum permissible exposures MPE) to radiofrequency electromagnetic
fields are usually expressed in terms of the plane wave equivalent power
density expressed in units of milliwatts per square centimeter mW/cm2) or
alternatively, absorption of RF energy is a function of frequency as well as
BIB]
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PUBLIC COMMENT�T��"�|E��0��body size and other factors). The limits vary with frequency. Standards are
more restrictive for frequencies at and below 300 MHz. Higher intensity RF
exposures are allowed for frequencies between 300 MHz and 6000 MHz
than for those below 300 MHz.
In the frequency range from 100 MHz to 1500 MHz, exposure limits for
field strength and power density are also generally based on the MPE limits
found in Section 4.1 of IEEE Standard for Safety Levels with Respect to
Human Exposure to Radio Frequency Electromagnetic Fields, 3 kHz to 300
GHz," ANSI/IEEE C95.1-1992 IEEE, 1992, and approved for use as an
American National Standard by the American National Standards Institute
ANSI).
US Federal Communications Commission FCC) Exposure Standards
Table 1, Appendix A FCC LIMITS FOR MAXIMUM PERMISSIBLE
EXPOSURE MPE)
A) Limits for Occupational/Controlled Exposure
Frequency
Range MHz) Electric Field
Strength E)
V/m) Magnetic Field
Strength H)
A/m) Power Density
S)
mW/cm2) Averaging
Time E]2 H]2
or S minutes)
0.3-3.0 614 1.63 100)* 6
3.0-30 1842/f 4.89/f 900/f2)* 6
30-300 61.4 0.163 1.0 6
300-1500 f/300 6
6
1500-100,000 5
B) FCC Limits for General Population/Uncontrolled Exposure
Frequency Electric Field Magnetic Field Power Density Averaging
Range MHz) Strength E) Strength H) S) Time E]2 H]2
V/m) A/m) mW/cm2) or S minutes)
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PUBLIC COMMENT�T��"�|E��1��0.3-3.0 614 1.63 100)* 30
3.0-30 824/f 2.19/f 180/f2)* 30
30-300 27.5 0.073 0.2 30
300-1500 f/1500 30
30
1500-100,000 1.0
f frequency in MHz *Plane-wave equivalent power density
NOTE 1: Occupational/controlled limits apply in situations in which persons are exposed as a
consequence of their employment provided those persons are fully aware of the potential for exposure
and can exercise control over their exposure. Limits for occupational/controlled exposure also apply in
situations when an individual is transient through a location where occupational/controlled limits apply
provided he or she is made aware of the potential for exposure.
NOTE 2: General population/uncontrolled exposures apply in situations in which the general public may
be exposed, or in which persons that are exposed as a consequence of their employment may not be fully
aware of the potential for exposure or can not exercise control over their exposure. Source: FCC
Bulletin OET 65 Guidelines, page 67 OET, 1997.
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PUBLIC COMMENT�T��"�|E��2��In this report, the public safety limit for a smart meter is a combination of
the individual antenna frequency limits and how much power output they
create. A smart meter contains two antennas. One transmits at 915 MHz
and the other at 2405 MHz. They can transmit at the same time, and so their
effective radiated power is summed in the calculations of RF power density.
Their combined limit is 655 uW/cm2. This limit is calculated by formulas
from Table 1, Part B and is proportionate to the power output and specific
safety limit in MHz) of each antenna.
For the collector meter, with it's three internal antennas, the combined
public safety limit for time-averaged exposure is 571 MHz a more
restrictive level since it includes an additional 824 MHz antenna that has a
lower limit than either the 915 MHz or the 2405 MHz antennas). 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). The
proportionate power output of each antenna plus the safety limit for each
antenna frequency combines to give a safety limit for the collector meter of
571 uW/cm2. Where one collector meter is combined with multiple smart
meters, the combined limit is weighted upward by the additional smart
meters' contribution, and is 624 uW/cm2.
Continuous Exposure
FCC Bulletin OET 65 guidelines require the assumption of continuous
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PUBLIC COMMENT�T��"�|E��3��exposure in calculations. Duty cycles offered by the utilities are a fraction
of continuous use, and significantly diminish predictions of RF exposure.
At present, there is no evidence to prove that smart meters are functionally
unable to operate at higher duty cycles that some utilities have estimated
estimates vary from 1% to 12.5% duty cycle, and as high as 30%).
Confirming this is the Electric Power Research Institute EPRI) in its
Perspective on Radio-Frequency Exposure Associated with Residential
Automatic Meter Reading Technology EPRI, 2010) According to EPRI:
The technology not only provides a highly efficient method for
obtaining usage data from customers, but it also can provide up-to-
the-minute information on consumption patterns since the meter
readingLdevices can be programmed to provide data as often as
needed. Emphasis added
The FCC Bulletin OET 65 guidelines specify that continuous exposure
defined by the FCC OET 65 as 100% duty cycle) is required in calculations
where it is not possible to control exposures to the general public.
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. emphasis added)
FCC Bulletin OET 65, p, 10
Duty factor. The ratio of pulse duration to the pulse period of a
periodic pulse train. Also, may be a measure of the temporal
transmission characteristic of an intermittently transmitting RF
source such as a paging antenna by dividing average transmission
duration by the average period for transmissions. A duty factor of 1.0
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PUBLIC COMMENT�T��"�|E��4��corresponds to continuous operation.
emphasis added)
FCC Bulletin OET 65, p, 2
This provision then specifies duty cycles to be increased to 100%.
The FCC Guidelines OET 65) further address cautions that should be
observed for uncontrolled public access to areas that may cause exposure to
high levels of RF.
Re-radiation
The foregoing also applies to high RF levels created in whole or in part
by re-eradiation. A convenient rule to apply to all situations involving
RF radiation is the following:
1)
Do not create high RF levels where people are or could
reasonably be expected to be present, and 2) p]revent people
from entering areas in which high RF levels are necessarily
present.
2) Fencing and warning signs may be sufficient in many cases to
protect the general public. Unusual circumstances, the presence of
multiple sources of radiation, and operational needs will require
more elaborate measures.
3)
Intermittent reductions in power, increased antenna heights,
modified antenna radiation patterns, site changes, or some
combination of these may be necessary, depending on the
particular situation.
FCC OET 65, Appendix B, p. 79
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PUBLIC COMMENT�T��"�|E��5��Fencing, distancing, protective RF shielded clothing and signage warning
occupants not to use portions of their homes or properties are not feasible
nor desirable in public places the general public will spend time schools,
libraries, cafes, medical offices and clinics, etc) These mitigation strategies
may be workable for RF workers, but are unsuited and intolerable for the
public.
Reflections
A major, uncontrolled variable in predicting RF exposures is the degree to
which a particular location kitchen, bedroom, etc) will reflect RF energy
created by installation of one or more smart meters, or a collector meter and
multiple smart meters. The reflectivity of a surface is a measure of the
amount of reflected radiation. It can be defined as the ratio of the intensities
of the reflected and incident radiation. The reflectivity depends on the angle
of incidence, the polarization of the radiation, and the electromagnetic
properties of the materials forming the boundary surface. These properties
usually change with the wavelength of the radiation. The reflectivity of
polished metal surfaces is usually quite high such as stainless steel and
polished metal surfaces typical in kitchens, for example).
Reflections can significantly increase localized RF levels. High uncertainty
exists about how extensive a problem this may create in routine installations
of smart meters, where the utility and installers have no idea what kind of
reflectivity is present within the interior of buildings.
Reflections in Equation 6 and 10 of the FCC OET Bulletin 65 include rather
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PUBLIC COMMENT�T��"�|E��6��minimal reflection factors of 100% and 60%, respectively. This report
includes higher reflection factors in line with published studies by Hondou et
al, 2006, Hondou, 2002 and Vermeeren et al, 2010. Reflection factors are
modeled at 1000% and 2000% as well as at 60% and 100%, based on
published scientific evidence for highly reflective environments. Hondou
2002) establishes that power density can be higher than conventional
formulas predict using standard 60% and 100% reflection factors.
We show that this level can reach the reference level ICNIRP
Guideline) in daily life. This is caused by the fundamental properties
of electromagnetic field, namely, reflection and additivity. The level
of exposure is found to be much higher than estimated by
conventional framework of analysis that assumes that the level rapidly
decreases with the inverse square distance between the source and the
affected person.
Since the increase of electromagnetic field by reflective boundaries
and the additivity of sources has not been recognized yet, further
detailed studies on various situations and the development of
appropriate regulations are required.
Hondou et al 2006) establishes that power densities 1000 times to 2000
times higher than the power density predictions from computer modeling
that does not account properly for reflections) can be found in daily living
situations. Power density may not fall off with distance as predicted by
formulas using limited reflection factors. The RF hot spots created by
reflection can significantly increase RF exposures to the public, even above
current public safety limits.
We confirm the significance of microwave reflection reported in our
previous Letter by experimental and numerical studies. Furthermore,
we show that hot spots' often emerge in reflective areas, where the
local exposure level is much higher than average.
BIB]
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PUBLIC COMMENT�T��"�|E��7��Our results indicate the risk of passive exposure' to microwaves.
The experimental values of intensity are consistently higher than
predicted values. Intensity does not even decrease with distance from
the source.
We further confirm the existence of microwave hotspots in which he
microwaves are localized'. The intensity measured at one hot spot
4.6 m from the transmitter is the same as that at 0.1 m from the
transmitter in the case with out reflection free boundary condition).
Namely, the intensity at the hot spot is increased by approximately
2000 times by reflection. Emphasis added
To confirm our experimental findings of the greater-than-predicted
intensity due to reflection, as well as the hot spots, we performed two
numerical simulations... intensity does not monotonically decrease
from the transmitter, which is in clear contrast to the case without
reflection.
The intensity at the hot spot X, Y, Z) 1.46, 0.78, 105) around 1.8
m from the transmitter in the reflective boundary condition is
approximately 1000 times higher than that at the same position in the
free boundary condition. The result of the simulation is thus
consistent with our experiments, although the values differ owing to
the different conditions imposed by computational limits.
Emphasis added
t)he result of the experiment is also reproduced: a greater than
predicted intensity due to reflection, as well as the existence of hot
spots.
In comparison with the control simulation using the free boundary
condition, we find that the power density at the hot spot is increased
by approximately a thousand times by reflection.
Emphasis added
Further, the author comments that:
we may be passively exposed beyond the levels reported for electro-
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PUBLIC COMMENT�T��"�|E��8��medical interference and health risks.
Because the peak exposure level is crucial in considering electro-
medical interference, interference in) airplanes, and biological
effects on human beings, we also need to consider the possible peak
exposure level, or hot spots'. for the worst-case estimation.
Reflections and re-radiation from common building material tile, concrete,
stainless steel, glass, ceramics) and highly reflective appliances and
furnishings are common in kitchens, for example. Using only low
reflectivity FCC equations 6 and 10 may not be informative. Published
studies underscore how use of even the highest reflection coefficient in FCC
OET Bulletin 65 Equations 6 and 10 likely underestimate the potential for
reflection and hot spots in some situations in real-life situations.
This report includes the FCC's reflection factors of 60% and 100%, and also
reflection factors of 1000% and 2000% that are more in line with those
reported in Hondou, 2001; Hondou, 2006 and Vermeeren et al, 2010. The
use of a 1000% reflection factor in this report is still conservative in
comparison to Hondou, 2006. A 1000% reflection factor is 12% of
Hondou's larger power density prediction or 121 times, rather than 1000
times)/ The 2000% reflection factor is 22% of Hondou's figure or 441 times
in comparison to 2000 times higher power density in Hondou, 2006).
Peak Power Limits
In addition to time-averaged public safety limits that require RF exposures to
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PUBLIC COMMENT�T��"�|E��9��be time-averaged over a 30 minute time period, the FCC also addresses peak
power exposures. The FCC refers back to the ANSI/IEEE C95.1-1992
standard to define what peak power limits are.
The ANSI/IEEE C95.1-1999 standard defines peak power density as the
maximum instantaneous power density occurring when power is
transmitted." p. 4) Thus, there is a second method to test FCC compliance
that is not being assessed in any FCC Grants of Authorization.
Note that although the FCC did not explicitly adopt limits for peak
power density, guidance on these types of exposures can be found in
Section 4.4 of the ANSI/IEEE C95.1-1992 standard.
Page 10, OET 65
The ANSI/IEEE limit for peak power to which the FCC refers is:
For exposures in uncontrolled environments, the peak value of the
mean squared field strengths should not exceed 20 times the square of
the allowed spatially averaged values Table 2) at frequencies below
300 MHz, or the equivalent power density of 4 mW/cm2 for between
300 MHzand6GHz".
The peak power exposure limit is 4000 uW/cm2 for all smart meter
frequencies all transmitting antennas) for any instantaneous RF exposure of
4 milliwatts/cm2 4 mW/cm2) or higher which equals 4000 microwatts/cm2
uW/cm2).
This peak power limit applies to all smart meter frequencies for both the
smart meter two-antenna configuration) and the collector meter three-
antenna configuration). All these antennas are within the 300 MHz to 6
GHz frequency range where the 4000 uW/cm2 peak power limit applies
BIB]
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PUBLIC COMMENT�T��"�|E��:��Table 3, ANSI/IEEE C95.1-1999, page 15).
Smart meters emit frequencies within the 800 MHz to 2400 MHz range.
Exclusions
This peak power limit applies to all parts of the body with the important
exception of the eyes and testes.
The ANSI/IEEE C95.1-1999 standard specifically excludes exposure of the
eyes and testes from the peak power limit of 4000 uW/cm2*. However,
nowhere in the ANSI/IEEE nor the FCC OET 65 documents is there a lower,
more protective peak power limit given for the eyes and testes see also
Appendix C).
The following relaxation ofpower density limits is allowed for
exposure of all parts of the body except the eyes and testes. p.15)
Since most exposures are not to uniform fields, a method has been
derived, based on the demonstrated peak to whole-body averaged SAR
ratio of 20, for equating nonuniform field exposure and partial body
exposure to an equivalent uniform field exposure. This is used in this
standard to allow relaxation ofpower density limits for partial body
exposure, except in the case of the eyes and the testes. p.20)
In the case of the eyes and testes direct relaxation ofpower density
limits is not permitted. p. 30)
*Note: This leaves unanswered what instantaneous peak power is permissible from smart meters.
The level must be below 4000 uW/cm2. This report shows clearly that smart meters can create
instantaneous peak power exposures where the face eyes) and body testes) are going to be in
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PUBLIC COMMENT�T��"�|E��;��close proximity to smart meter RF pulses. RF levels at and above 4000 uW/cm2 are likely to
occur if a person puts their face close to the smart meter to read data in real time. The digital
readout of the smart meter requires close inspection, particularly where there is glare or bright
sunlight, or low lighting conditions. Further, some smart meters are installed inside buildings
within inches of occupied space, virtually guaranteeing exposures that may violate peak power
limits. Violations of peak power limits are likely in these circumstances where there is proximity
within about 6" and highly reflective surfaces or metallic objects. The eyes and testes are not
adequately protected by the 4000 uW/cm2 peak power limit, and in the cases described above,
may be more vulnerable to damage Appendix C for further discussion).
METHODOLOGY
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.'
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= PxGx8 EIRPx0 1.64xERPxa
4 x n x R 2 4xirxR2 4xitxR2
where:
S power density in W/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
a 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
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PUBLIC COMMENT�T��"�|E��<��EIRP PG
ERP 1.64 EIRP
where
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.
a. Transmitter Power Output TPO) used is as shown on the grant
issued by the Telecommunications Certification Body TCB).
b. 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)
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PUBLIC COMMENT�T��"�|E��=��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.
a. Transmitter Power Output TPO) used is as shown on the grant
issued by the Telecommunications Certification Body TCB).
b. 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
Red figures used to ACS and TCB Certifi cation data sheet
Calculate ERP SK9AMI-2A SK9AMI-4
ACS TCB ACS TCB
Radio Frequency dBm Watts dBi Watts dBm Watts dBi Watts
GSM 850 31.8 1.5136 1.0
LAN 915 21.92 0.1556 3.0 24.27 0.2673 2.2 0.267
LAN 916 0.257
GSM 1900 28.7 0.7413 1.0
Register, 2405 18.71 0.0743 1.0 0.074 19.17 0.0826 4.4
Cell Relay 2480 14.00 0.00004 4.00
Assumptions: TPO per TCB Antenna Gain per ACS Certification
ERP Calculation: Bold figures are used for single meter ERP in modeling
Type TPO dBi dB Mult ERP Fre
1900 GSM 0.741 1.0 1.15 0.77 0.5689 1900
850 GSM 1.514 1.0 3.15 0.48 0.7328 850
RFLAN 0.267 2.2 0.05 1.01 0.2704 915
ZIG BEE 0.074 1.0 1.15 0.77 0.0570 2405
odel
SK9AMI-4
SK9AMI-2A
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PUBLIC COMMENT�T��"�|E��>��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 2.56times
100% I + 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 a:
1% 50%
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PUBLIC COMMENT�T��"�|E��?��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.
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
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PUBLIC COMMENT�T��"�|E��@��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.
* 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.
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
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PUBLIC COMMENT�T��"�|E��A��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
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PUBLIC COMMENT�T��"�|E��B��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
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PUBLIC COMMENT�T��"�|E��C��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.
RESULTS, FINDINGS AND CONCLUSIONS
The installation of wireless smart meters' in California can produce
significantly high levels of radiofrequency radiation RF) depending on
many factors location of meter(s) in relation to occupied or usable space,
duty cycle or frequency of RF transmissions, reflection and re-radiation of
RF, multiple meters at one location, collector meters, etc).
Power transmitters that will relay information from appliances inside
buildings with wireless smart meters produce high, localized RF pulses.
Any appliance that contains a power transmitter for example, dishwashers,
washers, dryers, ranges and ovens, convection ovens, microwave ovens,
flash water heaters, refrigerators, etc) will create another layer of RF
signals' that may cumulatively increase RF exposures from the smart
meter(s).
It should be emphasized that no single assertion of compliance can
adequately cover the vast number of site-specific conditions in which smart
meters are installed. These site-specific conditions determine public
exposures and thus whether they meet FCC compliance criteria.
BIB]
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PUBLIC COMMENT�T��"�|E��D��Tables in this report show either distance to an FCC safety limit in inches)
or they show the predicted calculated) RF level at various distances in
microwatts per centimeter squared uW/cm2).
Both depictions are useful to document and understand RF levels produced
by smart meters or multiple smart meters) and by collector meters or
collections of one collector and multiple smart meters).
Large differences in the results of computer modeling occur in this report by
bracketing the uncertainties running a sufficient number of computer
scenarios) to account for variability introduced by possible duty cycles and
possible reflection factors.
FCC equations from FCC OET 65 provide for calculations that incorporate
60% or 100% reflection factors. Studies cited in this report document higher
possible reflections in highly reflective environments) and support the
inclusion of higher reflection factors of 1000% and 2000% based on
Vermeeren et al, 2010, Hondou et al, 2006 and Hondou, 2002. Tables in the
report provide the range of results predicted by computer modeling for duty
cycles from 1 % to 100%, and reflection factors of 60%, 100%, 1000%, and
2000% for comparison purposes. FCC violations of time-weighted average
calculations and peak power limit calculations come directly from FCC OET
65 and from ANSI/IEEE c95.1-1992, 1999. Duty cycle or how frequently
the meters will produce RF transmissions leading to elevated RF exposures)
is uncertain, so the full range of possible duty cycles are included, based on
best available information at this date.
BIB]
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15913-U05
2-U06
ACCEPT-U07
A-U07
WRITTEN-U07
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DR.-U07
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STALLWORTH,-U07
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OF-U07
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SMART-U07
METERS-U07
411-HEALTH-U08
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PUBLIC COMMENT�T��"�|E��E�� Tables 1-2 show radiofrequency radiation RF) levels at 6" to
represent a possible face exposure). These are data tables.
Tables 3-4 show RF levels at 11" to represent a possible
nursery/bedroom exposure). These are data tables.
Tables 5-6 show RF levels at 28" to represent a possible kitchen
work space exposure. These are data tables.
Tables 7-9 show the distance to the FCC violation level for time-
weighted average limits and for peak power limits in inches). These
are data tables.
Tables 10-15 show where FCC violations may occur at the face, in
the nursery or in the kitchen scenarios. These are colored tables
highlighting where FCC violations may occur under all scenarios.
Tables 16-29 show comparisons of smart meter RF levels with
studies that report adverse health impacts from low-intensity, chronic
exposure to similar RF exposures. These are colored tables
highlighting where smart meter RF levels exceed levels associated
with adverse health impacts in published scientific studies.
Tables 30-31 show RF levels in comparison to Medtronics advisory
limit for MRI exposures to radiofrequency radiation at 0.1 W/Kg or
about 250 uW/cm2. These are colored tables highlighting where smart
meter RF levels may exceed those recommended for RF exposure.
Tables 32-33 show RF levels from smart meters in comparison to
the Biolnitiative Report recommendation of 0.1 uW/cm2 for chronic
exposure to pulsed radiofrequency radiation.
Findings
RF levels from the various scenarios depicting normal installation and
BIB]
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PUBLIC COMMENT�T��"�|E��F��operation, and possible FCC violations have been determined based on both
time-averaged and peak power limits Tables 1 14).
Potential violations of current FCC public safety standards for smart meters
and/or collector meters in the manner installed and operated in California are
illustrated in this Report, based on computer modeling Tables 10 17).
Tables that present data, possible conditions of violation of the FCC public
safety limits, and comparisons to health studies reporting adverse health
impacts are summarized Tables 18 33).
Where do predicted FCC violations occur for the 655 u W/cm2 time-
averaged public safety limit at the face at 6" distance from the meter?
Table 10 shows that for one smart meter, no violations are predicted to occur
at 60% or 100% reflection factor at any duty cycle, but violations are
predicted to occur with nearly all scenarios using either 1000% or 2000%
reflection factors.
Table 10 also shows that for multiple smart meters, FCC violations are
predicted to occur at 60% reflection factor 50% to 100% duty cycles; and
also at 100% reflection factor 30% to 100% duty cycle. All scenarios
using either 1000% or 2000% reflection factors indicate FCC violations can
occur or conservatively at 12% to 22% of those in Hondou et al, 2006).
Table 11 shows that for one collector meter, one violation occurs at 60%
100% duty cycle; and at 100% reflection factor for duty cycles between 60%
and 100%. Violations are predicted to occur at all scenarios using either
1000% or 2000% reflection factors.
Table 11 also shows that for one collector meter plus multiple smart meters,
FCC violations can occur at 60%reflection factor 40% to 100% duty
cycles; and also at 100% reflection factor 30% to 100% duty cycle. All
scenarios using either 1000% or 2000% reflection factors indicate FCC
violations can occur.
BIB]
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GENERAL-U03
DOCUMENTS-U03
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15913-U05
2-U06
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A-U07
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OF-U07
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METERS-U07
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PUBLIC COMMENT�T��"�|E��G��Where do predicted FCC violations occur for the 655 uW/cm2 time-
averaged public safety limit in the nursery crib at 11 distance?
Table 12 shows that for one smart meter, no violations are predicted to occur
at 60% or 100% reflection factor at any duty cycle, but violations would be
predicted with nearly all scenarios using either 1000% or 2000% reflection
factors.
Table 12 also shows that for multiple smart meters, no FCC violations are
predicted to occur at 60% reflection factor at any duty cycle; and also at
100% reflection factor 90% and 100% duty cycle. All scenarios using
either 1000% or 2000% reflection factors indicate FCC violations can occur.
Table 13 shows that for one collector meter, one violation occurs at 100%
reflection 100% duty cycle. No violations at 60% reflection are predicted.
Violations are predicted to occur at all scenarios using 1000% reflection
except I% duty cycle. All 2000% reflection scenarios indicate FCC
violations can occur.
Table 13 shows that for one collector meter plus multiple smart meters, FCC
violations are not predicted to occur at 60% reflection factor. At 100%
reflection factor, violations are predicted at 60% to 100% duty cycles. FCC
violations are predicted for all1000% and 2000% reflection factors with the
exception of 1000% reflection at I% duty cycle.
Where do predicted FCC violations occur for the 655 uW/cm2 time-
averaged public safety limit in the kitchen work space at 28" distance?
Table 14 shows that for one smart meter, no violations are predicted to occur
at 60% or 100% reflection factor at any duty cycle. Violations would be
predicted with scenarios of 1000% reflection 70% to 100% duty cycles
and at 2000% reflection factor 20% to 100% duty cycles.
Table 14 also shows that for multiple smart meters, no FCC violations are
predicted to occur at 60% or at the 100% reflection factors at any duty cycle.
Violations are predicted at 1000% reflection factor 70% to 100% duty
cycles and at 2000% reflection factor 20% to 100% duty cycles.
BIB]
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A-U07
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PUBLIC COMMENT�T��"�|E��H��Table 15 shows that for one collector meter, one violation occurs at 100%
reflection 100% duty cycle. No violations at 60% reflection are predicted.
Violations are predicted to occur at all scenarios using 1000% reflection
except 1% duty cycle. All 2000% reflection scenarios indicate FCC
violations can occur.
Table 15 shows that for one collector meter plus multiple smart meters, FCC
violations are not predicted to occur at 60% or at 100% reflection factors at
any duty cycle. At 1000% reflection factor, violations are predicted at 30%
to 100% duty cycles. FCC violations are also predicted at 2000% reflection
factor 10 to 100% duty cycles.
Where can peak power limits be violated? The peak power limit of 4000
uW/cm2 instantaneous public safety limit at 3 distance? This limit may be
exceeded wherever smart meters and collector meters face plate or any
portion within 3 of the internal antennas can be accessed directly by the
public.
Table 16 shows that for one smart meter, no violations are predicted to occur
at 60% or 100% reflection factor at any duty cycle. Peak power limit
violations would be predicted with scenarios of 1000% reflection 10% to
100% duty cycles and at 2000% reflection factor 10% to 100% duty
cycles.
Table 16 also shows that for multiple smart meters, peak power limit
violations are predicted to occur at 60% reflection 60% to 100% duty
cycle and for 100% reflection 40% to 100% duty cycles. Violations are
predicted at 1000% reflection factor 10% to 100% duty cycles and at
2000% reflection factor 1% to 100% duty cycles.
Table 17 shows that for one collector meter, peak power limit violations are
predicted to occur at 60% reflection 80% to 100% duty cycles and at
100% reflection 50% to 100% duty cycles. Violations of peak power
limit are predicted to occur at all scenarios using 1000% reflection except
1%; and for 2000% reflection violations of peak power limit are predicted at
all duty cycles.
BIB]
40611-U01
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FO97017-U03
MG97055-U03
AS97081-U03
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AI97504-U03
DO98158-U03
C1-U03
GENERAL-U03
DOCUMENTS-U03
1/31/2011-U04
BORENM-U04
15913-U05
2-U06
ACCEPT-U07
A-U07
WRITTEN-U07
REPORT-U07
DR.-U07
HUGH-U07
STALLWORTH,-U07
DIRECTOR-U07
OF-U07
PUBLIC-U07
HEALTH/HEALTH-U07
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SMART-U07
METERS-U07
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PUBLIC COMMENT�T��"�|E��I��Table 17 shows that for one collector meter plus multiple smart meters, peak
power limit violations are predicted to occur at 60% 40% to 100% and
100% reflection 30% to 100% duty cycles. At 1000% and 2000%
reflection factors, peak power limit violations are predicted at all duty
cycles.
Where are RF levels associated with inhibition of DNA repair in human
stem cells at 92.5 uW/cm2 exceeded the in the nursery crib at 11 distance?
Table 18 shows that for one smart meter, RF exposures associated with
inhibition of DNA repair in human stem cells are predicted to occur at 60%
reflection factor@ 70% to 100% duty cycles, and at 100% reflection factor
50% to 100% duty cycles. All scenarios using either 1000% or 2000%
reflection factors exceed these RF exposures except 1000% at 1 % duty
cycle.
Table 18 also shows that for multiple smart meters, RF exposures associated
with inhibition of DNA repair in human stem cells are predicted to occur at
60% reflection factor@ 20% to 100% duty cycles, and at 100% reflection
factor 20% to 100% duty cycles. All scenarios using either 1000% or
2000% reflection factors exceed these RF exposure levels except 1000% at
1% duty cycle.
Table 19 shows that for one collector meter, RF exposures associated with
inhibition of DNA repair in human stem cells are predicted to occur at 60%
reflection factor@ 30% to 100% duty cycles, and at 100% reflection factor
20% to 100% duty cycles. All scenarios using either 1000% or 2000%
reflection factors exceed these RF exposure levels.
Table 19 shows that for one collector meter plus multiple smart meters, RF
exposures associated with inhibition of DNA repair in human stem cells are
predicted to occur at 60% reflection factor@ 20% to 100% duty cycles, and
at 100% reflection factor 10% to 100% duty cycles. All scenarios using
either 1000% or 2000% reflection factors exceed these RF exposure levels.
Where are RF levels associated with pathological leakage of the blood-brain
barrier at 0.4 8 uW/cm2 exceeded the in the nursery crib at 11 distance?
BIB]
40611-U01
PUBLIC-U02
COMMENT-U02
LI21329-U03
FO96183-U03
FO96184-U03
FO97017-U03
MG97055-U03
AS97081-U03
AS97083-U03
AI97504-U03
DO98158-U03
C1-U03
GENERAL-U03
DOCUMENTS-U03
1/31/2011-U04
BORENM-U04
15913-U05
2-U06
ACCEPT-U07
A-U07
WRITTEN-U07
REPORT-U07
DR.-U07
HUGH-U07
STALLWORTH,-U07
DIRECTOR-U07
OF-U07
PUBLIC-U07
HEALTH/HEALTH-U07
OFFICER-U07
REGARDING-U07
SMART-U07
METERS-U07
411-HEALTH-U08
MCKEE-U09
SUSIE-U09
MCKEES-U10
12/28/2010-U011
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2010.20).-U012
PUBLIC COMMENT�T��"�|E��J��Table 20 shows that for one smart meter, RF exposures associated with
pathological leakage of the blood-brain barrier at 8 uW/cm2 are predicted to
occur at 60% reflection factor@ 10% to 100% duty cycles, and at 100%
reflection factor 5% to 100% duty cycles. RF levels at 0.4 uW/cm2 the
lower end of the range) are exceeded at all duty cycles and at all reflection
factors in the nursery in the crib.
Table 20 also shows that for multiple smart meters, RF exposures associated
with pathological leakage of the blood-brain barrier at 8 uW/cm2 are
predicted to occur at 60% reflection factor@ 5% to 100% duty cycles, and at
100% reflection factor 5% to 100% duty cycles. RF levels at 0.4
uW/cm2 the lower end of the range) are exceeded at all duty cycles and at
all reflection factors in the nursery in the crib.
Table 21 shows that for one collector meter, RF exposures associated with
pathological leakage of the blood-brain barrier at 8 uW/cm2 are predicted to
occur at 60% reflection factor@ 5% to 100% duty cycles, and at 100%
reflection factor 5% to 100% duty cycles. RF levels at 0.4 uW/cm2 the
lower end of the range) are exceeded at all duty cycles and at all reflection
factors in the nursery in the crib.
Table 21 shows that for one collector meter plus multiple smart meters, RF
exposures associated with pathological leakage of the blood-brain barrier at
8 uW/cm2 are predicted to occur at 60% reflection factor@ 5% to 100%
duty cycles, and at 100% reflection factor 1% to 100% duty cycles. RF
levels at 0.4 uW/cm2 the lower end of the range) are exceeded at all duty
cycles and at all reflection factors in the nursery in the crib.
Where are RF levels associated with adverse neurological symptoms,
cardiac problems and increased cancer risk exceeded in the nursery crib at
11 distance?
Table 22 shows that for one smart meter, RF exposures associated with
adverse neurological symptoms above 0.1 uW/cm2 are exceeded at all duty
cycles and at all reflection factors in the nursery in the crib.
Table 22 shows that for multiple smart meters, RF exposures associated with
adverse neurological symptoms above 0.1 uW/cm2 are exceeded at all duty
BIB]
40611-U01
PUBLIC-U02
COMMENT-U02
LI21329-U03
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FO96184-U03
FO97017-U03
MG97055-U03
AS97081-U03
AS97083-U03
AI97504-U03
DO98158-U03
C1-U03
GENERAL-U03
DOCUMENTS-U03
1/31/2011-U04
BORENM-U04
15913-U05
2-U06
ACCEPT-U07
A-U07
WRITTEN-U07
REPORT-U07
DR.-U07
HUGH-U07
STALLWORTH,-U07
DIRECTOR-U07
OF-U07
PUBLIC-U07
HEALTH/HEALTH-U07
OFFICER-U07
REGARDING-U07
SMART-U07
METERS-U07
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2010.20).-U012
PUBLIC COMMENT�T��"�|E��K��cycles and at all reflection factors in the nursery in the crib.
Table 23 shows that for one collector meter, RF exposures associated with
adverse neurological symptoms above 0.1 uW/cm2 are exceeded at all duty
cycles and at all reflection factors in the nursery in the crib.
Table 23 shows that for one collector meter plus multiple smart meterss, RF
exposures associated with adverse neurological symptoms above 0.1
uW/cm2 are exceeded at all duty cycles and at all reflection factors in the
nursery in the crib.
Where are RF levels associated with inhibition of DNA repair in human
stem cells at 92.5 uW/cm2 exceeded the in the kitchen work space at 28
distance?
Table 24 shows that for one smart meter, RF levels do not exceed those
associated with inhibition of DNA repair at 60% or 100% reflection factor at
any duty cycle. RF levels are exceeded at 1000% 10% to 100% duty
cycles; and at 2000% reflection factor 5% to 100% duty cycles.
Table 24 also shows that for multiple smart meters, RF levels do not exceed
those associated with inhibition of DNA repair at 60% or 100% reflection
factor at any duty cycle. RF levels are exceeded at 1000% 5% to 100%
duty cycles; and at 2000% reflection factor I% to 100% duty cycles.
Table 25 shows that for one collector meter, RF levels do not exceed those
associated with inhibition of DNA repair at 60% at any duty cycle; at 100%
reflection factor they are exceeded at 70% to 100% duty cycles RF levels
are exceeded at 1000% 5% to 100% duty cycles; and at 2000% reflection
factor I% to 100% duty cycles.
Table 25 shows that for one collector meter plus multiple smart meters, RF
levels exceed those associated with inhibition of DNA repair at 60%
reflection@ 100% duty cycle; at 100% reflection factor they are exceeded at
70% to 100% duty cycles RF levels are exceeded at 1000% 5% to
100% duty cycles; and at 2000% reflection factor I% to 100% duty
cycles.
BIB]
40611-U01
PUBLIC-U02
COMMENT-U02
LI21329-U03
FO96183-U03
FO96184-U03
FO97017-U03
MG97055-U03
AS97081-U03
AS97083-U03
AI97504-U03
DO98158-U03
C1-U03
GENERAL-U03
DOCUMENTS-U03
1/31/2011-U04
BORENM-U04
15913-U05
2-U06
ACCEPT-U07
A-U07
WRITTEN-U07
REPORT-U07
DR.-U07
HUGH-U07
STALLWORTH,-U07
DIRECTOR-U07
OF-U07
PUBLIC-U07
HEALTH/HEALTH-U07
OFFICER-U07
REGARDING-U07
SMART-U07
METERS-U07
411-HEALTH-U08
MCKEE-U09
SUSIE-U09
MCKEES-U10
12/28/2010-U011
REFERRAL-U012
#-U012
2010.20).-U012
PUBLIC COMMENT�T��"�|E��L��Where are RF levels associated with pathological leakage of the blood-brain
barrier and neuron death at 0.4 8 uW/cm2 risk in the kitchen work space
at 28 distance?
Table 26 shows that for one smart meter, RF exposures associated with
pathological leakage of the blood-brain barrier at 8 uW/cm2 are predicted to
occur at 60% reflection factor@ 40% to 100% duty cycles, and at 100%
reflection factor 30% to 100% duty cycles, and at all 1000% and 2000%
reflections. RF levels at 0.4 uW/cm2 the lower end of the range) are
exceeded at all duty cycles and at all reflection factors in the kitchen work
space except at 1% duty cycle for 60% and 100% reflections.
Table 26 also shows that for multiple smart meters, RF exposures associated
with pathological leakage of the blood-brain barrier at 8 uW/cm2 are
predicted to occur at 60% reflection factor@ 30% to 100% duty cycles, and
at 100% reflection factor 20% to 100% duty cycles, and at all 1000% and
2000% reflections. RF levels at 0.4 uW/cm2 the lower end of the range)
are exceeded at all duty cycles and at all reflection factors in the kitchen.
Table 27 shows that for one collector meter, RF exposures associated with
pathological leakage of the blood-brain barrier at 8 uW/cm2 are predicted to
occur at 60% reflection factor@ 20% to 100% duty cycles, and at 100%
reflection factor 10% to 100% duty cycles. RF levels at 0.4 uW/cm2 the
lower end of the range) are exceeded at all duty cycles and at all reflection
factors in the kitchen work space.
Table 27 shows that for one collector meter plus multiple smart meters, RF
exposures associated with pathological leakage of the blood-brain barrier at
8 uW/cm2 are predicted to occur at 60% reflection factor@ 20% to 100%
duty cycles, and at 100% reflection factor 20% to 100% duty cycles. RF
levels at 0.4 uW/cm2 the lower end of the range) are exceeded at all duty
cycles and at all reflection factors in the kitchen work space.
Where are RF levels associated with adverse neurological symptoms,
cardiac problems and increased cancer risk in the kitchen work space at
28 distance?
Table 28 shows that for one smart meter, RF exposures associated with
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PUBLIC COMMENT�T��"�|E��M��adverse neurological symptoms above 0.1 uW/cm2 are exceeded at all duty
cycles and at all reflection factors in the kitchen work space.
Table 28 shows that for multiple smart meters, RF exposures associated with
adverse neurological symptoms above 0.1 uW/cm2 are exceeded at all duty
cycles and at all reflection factors in the kitchen work space.
Table 29 shows that for one collector meter, RF exposures associated with
adverse neurological symptoms above 0.1 uW/cm2 are exceeded at all duty
cycles and at all reflection factors in the kitchen work space.
Table 29 shows that for one collector meter plus multiple smart meterss, RF
exposures associated with adverse neurological symptoms above 0.1
uW/cm2 are exceeded at all duty cycles and at all reflection factors in the
kitchen work space.
Where do RF levels exceed the Medtronics Safety Advisory?
Table 30: At no duty cycles for either 60% or 100% reflection factors;
between 10% and 100% duty factors for 1000% and between 5% and 100%
duty factors for 2000% reflection for one smart meter).
Table 30: At 60% reflection 60% to 100% duty cycle; and at 100%
reflection 40% to 100% duty cycle; at 1000% reflection 5% to 100%
duty cycle and for all duty cycles at 2000% reflection for multiple smart
meters).
Table 31: At 60% reflection 70% to 100% duty cycle; at 100% reflection
at 50% to 100% duty cycles; at 1000% reflection 5% to 100% and at all
duty cycles for 2000% reflection for one collector meter).
Table 31: At 60% reflection 40% to 100% duty cycle; at 100% reflection
at 30% to 100% duty cycles; and at all duty cycles for both 1000% reflection
and for 2000% reflection for one collector meter plus three smart meters).
Where are RF levels associated with smart meters in all their configurations
one meter, multiple smart meters, one collector meter, one collector plus
multiple smart meters) above those recommended in the Biolnitiative Report
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PUBLIC COMMENT�T��"�|E��N��2007)?
Tables 32 and 33 depict the distance from the center of radiation for the
smart meter(s) and collector meter scenarios in feet. The distances in feet)
at which RF levels exceed the Biolnitiative Report recommended limit of
0.1 uW/cm2 is as small as 3.4' one smart meter at 60% reflection and I%
duty cycle). At 60% reflection and 100% duty cycle, the distance to the
Biolnitiative recommended limit increases to 34 feet for one smart meter.
When multiples of smart meters are considered, the shortest distance to
where the Biolnitiative Report recommended limit is exceeded is 9.7 feet
for 60% reflection 1% duty cycle). It increases to 97' 100% duty
cycle for multiple smart meters.
For a single collector meter, the shortest distance to a Biolnitiative Report
exceedence is 5.9 feet 60% reflection 1% duty cycle). At 60% reflection
and 100% duty cycle, it increases to 59 feet.
For a collector and multiple smart meters, the shortest distance is 10.9 feet at
60% reflection 1 % duty cycle, and increases to 108 feet at 100% duty
cycle.
Conclusions
FCC compliance violations are likely to occur under widespread conditions
of installation and operation of smart meters and collector meters in
California. Violations of FCC safety limits for uncontrolled public access
are identified at distances within 6" of the meter. Exposure to the face is
possible at this distance, in violation of the time-weighted average safety
limits Tables 10-11). FCC violations are predicted to occur at 60%
reflection and 100% reflection factors*, both used in FCC OET 65 formulas
for such calculations for time-weighted average limits. Peak power limits
are not violated at the 6" distance looking at the meter) but can be at 3"
from the meter, if it is touched.
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PUBLIC COMMENT�T��"�|E��O��This report has also assessed the potential for FCC violations based on two
examples of RF exposures in a typical residence. RF levels have been
calculated at distances of 11" to represent a nursery or bedroom with a crib
or bed against a wall opposite one or more meters); and at 28" to represent a
kitchen work space with one or more meters installed on the kitchen wall).
FCC compliance violations are identified at 11" in a nursery or bedroom
setting using Equation 10* of the FCC OET 65 regulations Tables 12-13).
These violations are predicted to occur where there are multiple smart
meters, or one collector meter, or one collector meter mounted together with
several smart meters.
FCC compliance violations are not predicted at 28" in the kitchen work
space for 60% or for 100% reflection calculations. Violations of FCC public
safety limits are predicted for higher reflection factors of 1000% and 2000%,
which are not a part of FCC OET 65 formulas, but are included here to allow
for situations where site-specific conditions highly reflective environments,
for example, galley-type kitchens with many highly reflective stainless steel
or other metallic surfaces) may be warranted see Methodology Section).
In addition to exceeding FCC public safety limits under some conditions of
installation and operation, smart meters can produce excessively elevated RF
exposures, depending on where they are installed. With respect to absolute
RF exposure levels predicted for occupied space within dwellings, or outside
areas like patios, gardens and walk-ways, RF levels are predicted to be
substantially elevated within a few feet to within a few tens of feet from the
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PUBLIC COMMENT�T��"�|E��P��meter(s).
For example, one smart meter at 11" from occupied space produces
somewhere between 1.4 and 140 microwatts per centimeter squared
uW/cm2) depending on the duty cycle modeled Table 12). Since FCC
OET 65 specifies that continuous exposure be assumed where the public
cannot be excluded such as is applicable to one's home), this calculation
produces an RF level of 140 uW/cm2 at 11" using the FCCs lowest
reflection factor of 60%. Using the FCC's reflection factor of 100%, the
figures rise to 2.2 uW/cm2 218 uW/cm2, where the continuous exposure
calculation is 218 uW/cm2 Table 12). These are very significantly elevated
RF exposures in comparison to typical individual exposures in daily life.
Multiple smart meters in the nursery/bedroom example at 11" are predicted
to generate RF levels from about 5 to 481 uW/cm2 at the lowest 60%)
reflection factor; and 7.5 to 751 uW/cm2 using the FCCs 100% reflection
factor Table 13). Such levels are far above typical public exposures.
RF levels at 28" in the kitchen work space are also predicted to be
significantly elevated with one or more smart meters or a collector meter
alone or in combination with multiple smart meters). At 28" distance, RF
levels are predicted in the kitchen example to be as high as 21 uW/cm2 from
a single meter and as high as 54.5 uW/cm2 with multiple smart meters using
the lower of the FCCs reflection factor of 60% Table 14).
Using the FCCs higher reflection factor of 100%, the RF levels are predicted
to be as high as 33.8 uW/cm2 for a single meter and as high as 85.8 uW/cm2
for multiple smart meters Table 14). For a single collector meter, the range
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PUBLIC COMMENT�T��"�|E��Q��is 60.9 to 95.2 uW/cm2 at 60% and 100% reflection factors, respectively)
from Table 15).
Table 16 illustrates predicted violations of peak power limit 4000 uW/cm2)
at 3" from the surface of a meter. FCC violations of peak power limit are
predicted to occur for a single collector meter at both 60% and 100%
reflection factors. This situation might occur if someone touches a smart
meter or stands directly in front.
Uncertainty About Actual RF Levels
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
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PUBLIC COMMENT�T��"�|E��R��space, depending on how the meter is located, building materials in the
structure, and how it is furnished.
People who are afforded special protection under the federal Americans with
Disabilities Act are not sufficiently acknowledged nor protected. People
who have medical and/or metal implants or other conditions rendering them
vulnerable to health risks at lower levels than FCC RF limits may be
particularly at risk Tables 30-31). This is also likely to hold true for other
subgroups, like children and people who are ill or taking medications, or are
elderly, for they have different reactions to pulsed RF. Childrens' tissues
absorb RF differently and can absorb more RF than adults Christ et al,
2010; Wiart et al, 2008). The elderly and those on some medications respond
more acutely to some RF exposures.
Eyes and Testes Safety standards for peak exposure limits to
radiofrequency have not been developed to take into account the particular
sensitivity of the eyes, testes and other ball shaped organs. There are no
peak power limits defined for the eyes and testes, and it is not unreasonable
to imagine situations where either of these organs comes into close contact
with smart meters and/or collector meters, particularly where they are
installed in multiples on walls of multi-family dwellings that are accessible
as common areas).
What can be determined from the relevant standards FCC and ANSI/IEEE
and certain IEEE committee documents is that the eye and testes are
potentially much more vulnerable to damage, but that there is no scientific
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PUBLIC COMMENT�T��"�|E��S��basis on which to develop a new, more protective safety limit. What is
certain is that the peak power limit of 4000 uW/cm2 exceeds what is safe
Appendix Q.
In summary, no positive assertion of safety can be made by the FCC, nor
relied upon by the CPUC, with respect to pulsed RF when exposures are
chronic and occur in the general population. Indiscriminate exposure to
environmentally ubiquitous pulsed RF from the rollout of millions of new
RF sources smart meters) will mean far greater general population
exposures, and potential health consequences. Uncertainties about the
existing RF environment how much RF exposure already exists), what kind
of interior reflective environments exist reflection factor), how interior
space is utilized near walls), and other characteristics of residents age,
medical condition, medical implants, relative health, reliance on critical care
equipment that may be subject to electronic interference, etc) and
unrestrained access to areas of property where meter is located all argue for
caution.
Electronic Interference
Consumers may experience electronic interference electromagnetic
interference or EMI) from smart meter wireless signals. The FCC also is
charged with investigating consumer complaints about electronic
interference.
The FCC requires that unlicensed low power RF devices must not
create interference and users of such equipment must resolve any
interference problems or cease operation. According to the FCC
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PUBLIC COMMENT�T��"�|E��T��47CFR Part 15): The operator of a radio frequency device shall be
required to cease operating the device upon notification by a
Commission representative that the device is causing harmful
interference. Operation shall not resume until the condition causing
the harmful interference has been corrected.
EPRI, 2010)
Medical and other critical care equipment in the home environment may not
work, or work properly due to electronic interference from smart meters.
Security systems, surveillance monitors and wireless intercoms may be
rendered inoperable or unreliable. Some cordless telephones do not work
reliably, or have substantial interference from smart meter RF emissions.
Electronic equipment and electrical appliances may be damaged or have to
be replaced with other, newer equipment in order not to be subject to
electromagnetic interference from smart meter RF bursts.
Americans With Disabilities Act
People who have medical implants, particularly metal implants, may be
more sensitive to spurious RF exposures for two reasons. Electromagnetic
interference EMI) with critical care medical equipment and medical
implants is a potentially serious threat. Patients with deep-brain stimulators
Parkinson's disease patients) have reported adverse health effects due to RF
from various environmental sources like security gates and RFID scanners.
Patients with deep brain stimulators have reported the devices to be
reprogramming or electrodes shut-down as a result of encounters with
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PUBLIC COMMENT�T��"�|E��U��wireless RFID scanners. One manufacturer, Medtronics, has issued a
warning for DBS implant patients to limit RF exposure to less than 0.1
W/Kg SAR or sixteen times lower than for the general public) for MRI
exposures.
The IEEE SC4 committee 2001) considered changes to existing ANSI/IEEE
standards adopted in 1992 C95.1-1992). They discussed vulnerable organs
eyes, testes) and metallic implants that can intensify localized RF exposures
within the body and its tissues.
Question 20: Are there specific tissues or points within the body that
have particularly high susceptibilities to local heating due to thermal
properties in the immediate vicinity of the tissue?
Committee minutes include the following discussion on metallic implants.
Metallic implants are an interesting example of this question. There
can be very localized high field concentrations around the tips of long
metal structures, in the gaps of wire loops. Of course, these metal
devices don't create energy, but can only redistribute it, so the effect
is limited to some extent. Also the high thermal conductivity and
specific heat capacity make them good thermal sinks for any localized
heat sources generated around them.
Since deep brain stimulators in Parkinson's patients involve metal implants
that are essentially long metal structures with tips that interface with brain
tissue and nerves within the brain and body, exposing such patients with
implants to high levels of pulsed RF that can produce localized, high RF
within the body is certainly inadvisable. It is clear the IEEE SC4 committee
recognized the potential risk by to calling such implanted metallic devices
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PUBLIC COMMENT�T��"�|E��V��good thermal sinks' for localized heating dissipation.
The FCC's Grants of Authorization and other certification procedures do not
ensure adequate safety to safeguard people under Department of Justice
protection under the Americans with Disabilities Act.
References
ANSI/IEEE standards adopted in 1992 C95.1-1992) and 1999 revisions
June 2001 SC-4 Committee Minutes
Christ A Gosselin MC Christopoulou M Kuhn S Kuster N. Age dependent
tissue-specific exposure of cell phone users. Physics in Medicine and
Biology, Volume 55, Issue 7, pp. 1767-1783, 7 April 2010, online March 5
EPRI, 2010. A Perspective on Radio-Frequency Exposure Associated With
Residential Automatic Meter Reading Technology, Electric Power Research
Institute, Palo Alto, CA.
Federal Communications Commission, 1997. FCC Bulletin OET 65 97-01
Guidelines Evaluating Compliance with FCC Guidelines for Human
BIB]
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PUBLIC COMMENT�T��"�|E��W��Exposure to Radiofrequency Electromagnetic Fields.
Hondou T Ueda T Sakat Y Tanigwa N Suzuki T Kobayashi T Ikeda K.
Passive Exposure to Mobile Phones: Enhancement of Intensity by
Reflection, Journal of the Physical Society of Japan Vol. 75, No. 8, August,
2006, 084801 2006) The Physical Society of Japan
Hondou T, Rising Level of Public Exposure to Mobile
Phones:Accumulation through Additivity and Reflectivity. Journal of the
Physical Society of Japan, Vol. 71, No. 2, February, 2002, pp. 432-435
2002) The Physical Society of Japan.
The Institute of Electrical and Electronic Engineers, Inc. 1999. IEEE
Standards Coordinating Committee 28, IEEE Standard for Safety Levels
with Respect to Human Exposure to Radio Frequency Electromagnetic
Fields 3 kHz to 300 GHz. December, 1998.
Khurana VG Hardell L Everaert J Bortkiewicz A Carlberg M Ahonen M,
2010. Epidemiological Evidence for a Health Risk from Mobile Phone Base
Stations. Int Journal of Occupational Environmental Health 2010;16:263-
267
Kundi M Hutter HP Mobile phone base stations-Effects on wellbeing and
health. Pathophysiology 16 2009) 123-135
Markova E Malmgren LOG Belyaev IY. Microwaves from mobile phones
inhibit 53PB 1 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
National Council on Radiation Protection and Measurements NCRP) in
Biological Effects and Exposure Criteria for Radiofrequency
Electromagnetic Fields," NCRP Report No. 86, Sections 17.4.1, 17.4.1.1,
17.4.2 and 17.4.3. Copyright NCRP, 1986, Bethesda, Maryland 20814
National Toxicology Program Fact Sheet, 2009). Cell Phone
Radiofrequency Radiation Studies, September 2009).
Vermeeren G Gosselin MC Gosselin Kuhn S Kellerman V Hadmen A Gati
A Joseph W Wiart J Meyer F Kuster N Martens L. The influence of the
BIB]
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PUBLIC COMMENT�T��"�|E��X��reflective environment on the absorption of a human male exposed to
representative base station antennas from 300 MHz to 5 GHz, Phys. Med.
Biol. 55 2010) 5541-5555 doi:10.1088/0031-9155/55/18/018
Wiart, J., Hadjem, A., Wong, M.F., & Bloch, I. 2008). Analysis of RF
exposure in the head tissues of children and adults. Physical Medicine &
Biology, 53, 3681-3695.
Appendix A Tables Al- A 48
RADIOFREQUENCY RADIATION VERSUS DISTANCE
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PUBLIC COMMENT�T��"�|E��Y��One Smart Meter
Table Al 60% Reflection 1%- 100% duty cycles in each table)
Table A2 100% Reflection 1 %- 100% duty cycles in each table)
Table A3 1000% Reflection* 1%- 100% duty cycles in each table)
Table A4 2000% Reflection* 1%- 100% duty cycles in each table)
Multiple Smart Meters Four**)
Table A5 60% Reflection 1 %- 100% duty cycles in each table)
Table A6 100% Reflection 1%- 100% duty cycles in each table)
Table A7 1000% Reflection 1 %- 100% duty cycles in each table)
Table A8 2000% Reflection 1 %- 100% duty cycles in each table)
One Collector Meter
Table AA9 60% Reflection 1%- 100% duty cycles in each table)
Table A 10 100% Reflection 1 %- 100% duty cycles in each table)
Table A l l 1000% Reflection 1 %- 100% duty cycles in each table)
Table A12 2000% Reflection l%- 100% duty cycles in each table)
One Collector Meter + 3 SM**
Table A 13 60% Reflection 1%- 100% duty cycles in each table)
Table A 14 100% Reflection 1 %- 100% duty cycles in each table)
Table A 15 1000% Reflection 1%- 100% duty cycles in each table)
Table A16 2000% Reflection 1%- 100% duty cycles in each table)
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PUBLIC COMMENT�T��"�|E��Z��TABLES OF CRITICAL DISTANCES IN NURSERY CRIB AT 11")
AND KITCHEN SINK AT 28") FROM SMART METER
A17-A48)
Table A17 Nursery Set
Table A18 One Smart Meter Critical Distance 11" to baby in crib
Table A 19 60%,100%,1000%,2000% duty cycle
Table A20 1% thru 90% duty cycle
Table A21 Nursery Set
Table A22 Eight Smart Meters Critical Distance 11" to baby in crib
Table A23 60%, 100%, 1000%, 2000% reflection
Table A241% thru 100% dutycycle
Table A25 Nursery Set
Table A26 One Collector- Critical Distance 11" to baby in crib
Table A27 60%,100%,1000%,2000% reflection
Table A281% thru 100% duty cycle
Table A29 Nursery Set
Table A30 One Collector Meter + 7 SM- Critical Distance 11" to baby
crib
Table A31 60%, 100%, 1000%, 2000% reflection
Table A32 1% thru 100% duty cycle
Table A33 Kitchen Set
Table A34 One Smart Meter Critical Distance 28" to kitchen sink person
Table A35 60%, 100%, 1000%, 2000% reflection
Table A36 1% thru 100% duty cycle
Table A37 Kitchen Set
Table A38 Eight Smart Meters Critical Distance 28" to kitchen sink
person
Table A39 60%, 100%, 1000%, 2000% reflection
Table A40 1 % thru 100% duty cycle
Table A41 Kitchen Set
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PUBLIC COMMENT�T��"�|E��[��Table A42 One Collector Critical Distance 28" to kitchen sink person
Table A43 60%, 100%, 1000%, 2000% reflection
Table A44 I% thru 100% duty cycle
Table A45 Kitchen Set
Table A46 One Collector + 7 SM Critical Distance 28" to kitchen
Table A47 60%,100%,1000%,2000% reflection
Table A48 I% thru 100% duty cycle
Appendix B Tables 1- 33 of Report
Data Tables, FCC Violation Tables, Health
Comparisions
Table 1 Radiofrequency Level at Each Duty Cycle and Reflection Factor at 6" in
uW/cm2 One Meter, Four Meters)
Table 2 Radiofrequency Level at Each Duty Cycle and Reflection Factor at 6" in
uW/cm2 One Collector, 1 C + 3 SM)
Table 3 RF Level of Each Duty Cycle and Reflection Factor at 11" in uW/cm2 in
the Nursery One meter, Four meters)
Table 4 RF Level of Each Duty Cycle and Reflection Factor at 11" in uW/cm2 in
the Nursery One Collector, 1 C + 3 SM)
Table 5 RF Level of Each Duty Cycle and Reflection Factor at 28" in uW/cm2 in
the Kitchen One Meter, Four Meters)
Table 6 RF Level of Each Duty Cycle and Reflection Factor at 28" in uW/cm2 in
the Kitchen One Collector, 1C + 3 SM)
Table 7 Distance at which FCC Safety Limit is exceeded for 655 uW/cm2 time-
weighted average limit One Meter, Four Meters)
Table 8 Distance at which FCC Safety Limit is exceeded for 571/624 uW/cm2
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PUBLIC COMMENT�T��"�|E��\��TWA limit One Collector, 1 C+ 3 Smart Meters)
Table 9 Distance at which FCC Safety Limit is exceeded for peak power limit of
4000 uW/cm2 1 SM, 4 SM; 1 Collector, 1 C + 3 SM)
Table 10 FCC Violations of the 655 uW/cm2 FCC limit at the face at 6"
One Meter, Four Meters)
Table 11 FCC Violations of the 571/624 uW/cm2 FCC limit at 6" at the face
One Collector, 1 C + 3 SM)
Table 12 FCC Violations of the 655 uW/cm2 FCC limit at 11" in the Nursery
One Meter, Four Meters)
Table 13 FCC Violations of the 571/624 uW/cm2 FCC limit at 11" in the Nursery
One Collector, 1C + 3 SM)
Table 14 FCC Violations of the 655 uW/cm2 FCC limit at 28" in the Kitchen
One Meter, Four Meters)
Table 15 FCC Violations of the 571/624 uW/cm2 FCC limit at 28" in the Kitchen
One Collector, 1C + 3 SM)
Table 16 Potential FCC Violations of Peak Power Limit of 4000 uW/cm2 at 3"
One SM, 4 SM)
Table 17 Potential FCC Violations of Peak Power Limit of 4000 uW/cm2 at 3"
One Collector, 1C + 3 SM)
Table 18 Nursery Radiofrequency Radiation Level Associated with Inhibition of
DNA Repair in Human Stem Cells 92.5 uW/cm2 with 24 and 72-hour
exposure Markova et al, 2009) One SM, 4 SM)
Table 19 Nursery Radiofrequency Radiation Level Associated with Inhibition of
DNA Repair in Human Stem Cells 92.5 uW/cm2 with 24 and 72-hour
exposure Markova et al, 2009) One Collector, 1 C + 3 SM)
Table 20 Nursery Radiofrequency Radiation Level Associated with Pathological
Leakage of the Blood-brain Barrier 0.4 to 8 uW/cm2 with chronic
exposure Persson et al, 1997) One SM, 4 SM)
Table 21 Nursery Radiofrequency Radiation Level Associated with Pathological
Leakage of the Blood-brain Barrier 0.4 to 8 uW/cm2 with chronic
exposure Persson et al, 1997) One Collector, 1 C + 3 SM)
Table 22 Nursery Radiofrequency Radiation Level Associated with Adverse Health
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PUBLIC COMMENT�T��"�|E��]��Symptoms from Cell Tower Studies 8 studies in total reporting sleep
disruption, headache, fatigue, memory loss, concentration difficulties,
irritability, increased cancer risk) 0.01 uW/cm2 with chronic exposure
Kundi, 2009; Khurana et al, 2010) One SM, 4 SM)
Table 23 Nursery Radiofrequency Radiation Level Associated with Adverse Health
Symptoms from Cell Tower Studies 8 studies in total reporting sleep
disruption, headache, fatigue, memory loss, concentration difficulties,
irritability, increased cancer risk) 0.01 uW/cm2 with chronic exposure
Kundi, 2009; Khurana et al, 2010) One Collector, 1 C + 3 SM)
Table 24 Kitchen Radiofrequency Radiation Level Associated with Inhibition of
DNA Repair in Human Stem Cells 92.5 uW/cm2 with 24 and 72-hour
exposure Markova et al, 2009) One SM, 4 SM)
Table 25 Kitchen Radiofrequency Radiation Level Associated with Inhibition of
DNA Repair in Human Stem Cells 92.5 uW/cm2 with 24 and 72-hour
exposure Markova et al, 2009) One Collector, 1 C + 3 SM)
Table 26 Kitchen Radiofrequency Radiation Level Associated with Pathological
Leakage of the Blood-brain Barrier 0.4 to 8 uW/cm2 with chronic
exposure Persson et al, 1997) One SM, 4 SM)
Table 27 Kitchen Radiofrequency Radiation Level Associated with Pathological
Leakage of the Blood-brain Barrier 0.4 to 8 uW/cm2 with chronic
exposure Persson et al, 1997) One Collector, 1 C + 3 SM)
Table 28 Kitchen Radiofrequency Radiation Level Associated with Adverse Health
Symptoms from Cell Tower Studies 8 studies in total reporting sleep
disruption, headache, fatigue, memory loss, concentration difficulties,
irritability, increased cancer risk) 0.01 uW/cm2 with chronic exposure
Kundi, 2009; Khurana et al, 2010) One SM, 4 SM)
Table 29 Kitchen Radiofrequency Radiation Level Associated with Adverse Health
Symptoms from Cell Tower Studies 8 studies in total reporting sleep
disruption, headache, fatigue, memory loss, concentration difficulties,
irritability, increased cancer risk) 0.01 uW/cm2 with chronic exposure
Kundi, 2009; Khurana et al, 2010) One Collector, 1 C + 3 SM)
Table 30 Radiofrequency Radiation Level Exceeds Medtronics Metal Implant
Advisory for MRI SAR Exposure of 0.1 W/Kg at Frequencies also Used
in Smart Meters at 11" One SM, 4 SM)
Table 31 Radiofrequency Radiation Level Exceeds Medtronics Metal Implant
Advisory for MRI SAR Exposure of 0.1 W/Kg at Frequencies also Used
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PUBLIC COMMENT�T��"�|E��^��in Smart Meters at 11" One Collector, 1 C + 3 SM)
Table 32 Predicted RF levels exceed Biolnitiative Report recommended limit of 0.1
uW/cm2 One SM, 4 SM)
Table 33 Predicted RF levels exceed Biolnitiative Report recommended limit of 0.1
uW/cm2 1 Collector 1C + 3 SM)
Appendix C
Other Sources of Information on sensitivity of
the eyes and testes
In the most recent proposed revisions of RF safety standards, the IEEE SC4
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PUBLIC COMMENT�T��"�|E��_��committee 2001) deliberated at length over the problem of peak power
limits and non-uniform RF exposure with respect to the eye and testes. The
quotes below come from committee drafts submitted in response to
questions from the committee moderator.
ANSI/IEEE standards adopted in 1992 C95.1-1992) and 1999 revisions
June 2001 SC-4 Committee Minutes
These committee discussions are informative on the issue of particular organ
sensitivity to RF, and unanswered questions and differences of opinion on
the subject among members. They discussed vulnerable organs eyes,
testes) and metallic implants that can intensify localized RF exposures
within the body and its tissues see also discussion on metallic implants).
Question 20: Are there specific tissues or points within the body that have
particularly high susceptibilities to local heating due to thermal properties
in the immediate vicinity of the tissue?
Committee minutes include the following discussion on the particular
sensitivities of ball shaped' organs including the eyes and testes.
Eye balls are commonly regarded as the critical organ"
In the range of a few GHz gigahertz), reasonances may occur in ball
shaped eyes and testes. They are also electrically and thermally partly
insulated from other tissues. Additionally these organs or some of their
parts lens) are thermally a little bit more vulnerable than other tissues.
m)odeling has noted that rapid changes in dialectrics such as cerebral
spinal fluid in the ventricles of the brain and surrounding brain tissue lead
to high calculated SARs. Secondly, exposure of the eye to microwave
radiation can lead to increased temperature that is sufficient to damage
tissues. The temperature rise will, of course, depend on the intensity of the
irradiation, how well the energy is coupled into tissues, and how well the
deposited energy is removed by normal mechanisms such as conduction and
blood flow. Microwaves at the lower frequencies will be deposited deeper in
the eye, while at higher frequencies they will be absorbed near the front
surface of the eye. The eye does not efficiently remove heat deposited
internally by microwave exposure. The main avenue of heat removal is
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PUBLIC COMMENT�T��"�|E��`��conduction and blood flow through the retina and choroid. The lens has
been thought to be the most vulnerable tissue since it has no blood flow.
Other than conduction through the sclera and convection from the surface of
the cornea, heat removal is poor compared to other body tissues. Because
the lens is avasular it has been thought to be particularly sensitive to
thermal effects of microwave exposure. These facts have led many
investigators to postulate that the poor heat dissipation from within the eye
of humans and other animals may lead to heat buildup and subsequent
thermal damage.
Eyes do not have good blood circulation and testes have lower than body
temperature.
These organs are not well-perfused, hence have been singled out for the
exclusion.
Are the above numbers valid for all parts of the body in all exposure
conditions over the time averaging period of the exposure? They the basic
limits) were derived in the manner you describe in body reasonance
conditions i.e. coherent exposure over the whole body length of a human.
Could the limit values of SAR be increased for partial body exposure? Yes,
but we do not have the data to make this decision. In the near field of a
source, clearly the limit value will depend on frequency depth of
penetration), organ blood supply and tolerance of that organism to sustain a
certain rate of temperature increase during the time averaging period and
the environmental conditions. If you have to deal with possible pathologies
of organs then matters become even more complicated, because you are
dealing not only with heat physiology, but also with general pathology,
whose books are much thicker than those on physiology.
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PUBLIC COMMENT�T��"�|E��a��Page 1 of 4
31W
i-11-t\
From: Glen Chase glenchase@aol.com]
Sent: Monday, January 10, 2011 3:34 AM
To: 112-Clerk of the Board Everyone; 100-District 1 831) 647-7991; 100-District 2 831) 755-5022;
100-District 3 831) 385-8333; 100-District 4 831) 883-7570; 100-District 5 831) 647-7755
Subject: Please Remove and Continue Consent Agenda #38 to later meeting
To: Monterey County Board of Supervisors
From: Professor Glen Chase
Re: Consent Agenda Item #38: Written Report from Hugh Stallworth, Health Officer regarding
Wireless smart meters Referral # 2010.20)
Date: January 9, 2011
Dear Supervisors,
Smart Meter Referral # 2010.20 from the Public Health Department Referral") is inaccurate, incorrect
and lacking support for its conclusions.
The Referral" is identical to PG&E's sales presentation to the public.
PG&E's own industry has vehemently criticized PG&E for misrepresenting issues to customers to the
extent that PG&E is jeopardizing a successful smart grid.
Two-dozen cities and counties have rejected PG&E's claims identical to the claims in this referral) and
taken various actions including resolutions against, moratorium ordinances and support for the Huffman
AB 37 bill, calling for a moratorium and opt-out choice.
a. The 1-watt label of Wireless smart meters and comparison to cell phones is deceiving by comparing
apples and oranges. That comparison would have a 100 watt light bulb being as damaging as 100 cell
phones, yet there are manufacturer warnings to keep a cell phone away from the head, and no need for
warnings on light bulbs.
b. PG&E Wireless smart meters transmit radiation constantly throughout the 24-hour day. PG&E
claiming only 45 seconds per day transmission is dishonest and the Public Health Department repeating
that is naive or irresponsible. PG&E is attempting to have the public believe that radiation
transmissions are limited to a short 45 second period per day, a time that is negligible as a percent of the
day and easy to avoid. That is false.
Pulsed signal radiation the type emitted by Wireless smart meters) is considerably more dangerous
than steady signal transmissions. Wireless smart meter pulses last only thousandths of a second, so
25,000 radiation pulses per day can occur from a single meter.
The same PG&E deceptive argument could similarly characterize a 24-hour wartime aerial bombing of
a city as only a five second attack, if only the times of detonations are added, since each bomb
detonation is just a tiny fraction of a second.
C. PG&E held 35 Information" meetings in Marin County not just 20 as in Monterey County) and at
1/10/2011
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PUBLIC COMMENT�T��"�|E��b��Page 2 of 4
the conclusion of those meetings, The Marin County Board of Supervisors unanimously passed an
Urgency Moratorium Ordinance disallowing PG&E Wireless smart meter installation and related
equipment.
Santa Cruz County had a three-month urgency ordinance from October to December 31, 2010. After
further investigation and no attempt by PG&E Corporate to respond to problems, the Santa Cruz
County Board of Supervisors has re-written and strengthened their ordinance and it is expected to pass
unanimously on Tuesday, January 11, 2011 for a full year.
d. Security: PG&E is currently attempting to legally relieve their responsibility and liability of damage
from third party access to customer information. The nature of Wireless meters creates security
problems that don't exist with wired options.
e. The data collected by PG&E Wireless Smart Meters is not accurate.
State Senator Florez held hearings on PG&E Wireless meter accuracy and increased utility bills and
Senator Florez commented that PG&E is lying to us.
Structure Group" did the report that pretended to validate PG&E wireless meters. Structure Group
admitted that they accepted information from PG&E and assumed that it was true. Structure Group is
in-bed with PG&E and PG&E is one of Structure Group's largest clients. Structure Group did not test
the Wireless meters as they are deployed in the field in a Mesh Network and they did not reconcile the
tens of thousands of complaints. Instead, they tested a small number of units in the laboratory, which
had already been done prior to the tens of thousands of complaints.
f. Opting out. The smart grid is intended to move energy from one region of the country where a
surplus is available to another region where demand has peaked due to weather or other customer
demands. This ability to Transfer" and receive energy from other regions reduces the number of
power plants required in each region for peak demands.
The smart grid does NOT require Smart Meters on every home. Only regional information is helpful,
not the energy usage of every single home.
As Nielson monitors only a tiny fraction of TV's in the United States to know with tremendous
accuracy what TV shows the people are watching, the Smart grid system similarly only requires a
sampling to know a region's usage.
Other Smart" systems in the United States do not require every person to participate. After multiple
complaints were filed, the PUC of Maine is currently reviewing the option of opt-out after approving a
comprehensive system.
Assemblyman Huffman's Bill AB 37 includes an opt-out choice and a moratorium until alternatives are
considered.
As the problems with Wireless meters are becoming more commonly known, even PG&E has admitted
that they are looking into alternatives for opting out from Wireless meters.
g. Wireless. The Federal smart grid program does NOT mandate Wireless meters.
1/10/2011
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The concept of Smart" is NOT connected to Wireless." PG&E creates that false connection with the
public because the public is attracted to Smart" and Wireless" allows PG&E to eliminate thousands of
jobs and realize huge windfall profits not shared with customers).
Other jurisdictions in the U.S. are installing wired systems fiber optics or other shielded cable systems)
for greater speed, greater security and for protecting people and the broader environment from the
signal radiation emitted by wireless meter transmissions.
Italy has installed a smart system with 25 million Wired meters.
Other European countries are changing from wireless to wired systems in utility smart meters and
Internet service in their schools. To my knowledge, NO country is moving from wired to wireless, only
from wireless to wired, as the problems with Wireless are becoming more widely known.
h. The FCC has not given assurance of safety of these PG&E Wireless meters.
PG&E has continued to NOT disclose pulsed peak information on these Wireless meters even though
elected officials and the public have requested that information for a long time now.
The public is told that these meters are modern technology replacing the old method of measuring
utility use. But the public does not realize that this program places a significant transmitting antenna
and receiving antenna on their home. If the public saw these antennas placed on their walls or roofs, or
even realized their strength, they would object, but because they are out of sight within the Wireless
meter enclosure, people don't realize it.
The manufacturers of the Wireless meters advertise that the signals go through mountains, quite
different than the image portrayed by PG&E Corporate.
Conclusion:
The Smart Meters Referral #2010.20 is not up to the quality standards that the Monterey Board of
Supervisors deserves to be familiar with the subject and certainly not to make decisions for the public
welfare.
There is no critical analysis in the Referral." Rather, it passes along a dishonest sales brochure of
PG&E Corporate to the Monterey County Board of Supervisors.
Please contact me if you have any questions.
If you decide to pull this item from the consent agenda and agendize this subject at a meeting beyond
January 11 and you would like me to speak, please let me know in advance.
I am a Professor of Systems Management. I integrate uncertain information from complex sciences to
develop management systems that can effectively operate NOW, without waiting years for better results
of the science.
1/10/2011
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PUBLIC COMMENT�T��"�|E��d��Page 4 of 4
ti
I own my home in Monterey County and I hate to see PG$E attempt to fool the representatives of our
county in a way that the tobacco industry did for most of a century.
Can you imagine cigarette smoking being mandatory for everyone in the home, including the youngest
of children, as PG&E Corporate is attempting with Wireless meters?
Please confirm that you have received this email communication.
Thanks for the service that you give to our community.
Give care, glen
Professor Glen Chase
glenchase aol. com
PS: Here are a few short Videos helping to visualize some of the information above:
1. Insurance Companies Won't Insure Wireless Devices due to Health Risks 3 minutes, 13 seconds)
http://eon3emfblog.net/?p=382
2. Radiation Measured From Smart Meter Mounted On A Home 6 minutes, 21 seconds)
http://www.youtube.com/watch?v=uRe-jDxBE60E
3. Senator Florez Meeting Skyrocketing Utility Bills after Wireless smart meter installation 3
minutes, 19 seconds)
http://www.bakersf-leldnow.com/news/63581287.html?tab=video
Here is a longer Video, extremely informative and valuable information from Top Scientists with
highest level of integrity.
4. In Depth Videos: World Renowned Scientists At The Commonwealth Club, Nov 18 2010, San
Francisco. 15 minutes each)
http://electromagnetichealth.org/electromagnetic-health-blo g/cc-video/
1/10/2011
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PUBLIC COMMENT�T��"�|E��e��From: marina meadows marinameadows@comcast.net]
Sent: Monday, January 10, 2011 8:16 PM
To: 112-Clerk of the Board Everyone
Subject: Smart Meters and the Sage Report
Importance: High
Attachments: SmartMeter Report.docx
Smart Meter_Repo
rt.dooc 89 KB...
Dear Supervisors,
We are very unhappy with Dr. Hugh Stallworth's recommendation that you accept Smart Meters
into Monterey County.
Please read and study the Sage Report we are attaching.
Many salient points are being missed; much disinformation is being disseminated by PG&E.
Too many issues are unaddressed.
Please take Item #38 off your agenda.
Please revisit this very grave concern of many Monterey County residents.
We need a town hall meeting to discuss.)
Something big is missing here... and it is the TRUTH.
We do not want Smart Meters on our homes and businesses!
They are unsafe, dangerous, invasive, expensive and unhealthy!
Thank you for thinking seriously about this issue and not going along with the Agenda 21
program.
Sincere Regards,
The Cecils
1
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PUBLIC COMMENT�T��"�|E��f��Page 1 of 1
From: S. Jack Lewtschuk blacklion@royal.net]
Sent: Tuesday, January 11, 2011 9:55 AM
To: 112-Clerk of the Board Everyone
Subject: New meters
PG&E arrived at my home to install the new meters unannounced.
Apparently they could not get to the wall due to vegetation.
Instead of knocking at my door I was at home all day) and tell me
that they are just outside and have a problem, they left.
A few days later, I received a call from PG&E.
I think that courtesy would dictate that a homeowner needs to be
notified when any work is to be done on his/her property.
Also, I am not yet persuaded that these meters are safe and/or
accurate.
S. Jack Lewtschuk
blacklion@roya/.net
1/11/2011
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PUBLIC COMMENT�T��"�|E��h��Page 1 of 4
From:
Sent:
To:
Subject: Chappell, Lori A. on behalf of 100-District 4 831)
Tuesday, January 11, 2011 1:30 PM
112-Clerk of the Board Everyone
FW: Smart Meter report, #38 consent agenda 883-7570
Follow Up Flag: Follow up
Flag Status: Green
Attachments: Marin Ordinance 3552.pdf; CPUC m EMFSN rehearing apppdf; Cindy Sage declaration
Jan 4, 2011.doc; Cindy Sage Smart Meter Report Jan, 2011.doc; Structure Group-
Bakersfield article 4-10.doc; Structure Group Report excerpt wo PG.doc
Sincerely,
Lori
Nappy New Years..
Office Manager I Supervisor Jane Parker
County of Monterey I Fourth District- Main Coastal Office
26161st Avenue, Marina CA 93933 I 831) 883-7571 phone
chappelllaPco.monterey.ca.us I www.janepaarker.org
be green. think before you print.
Original Message-----
From: nbeety@netzero.net mailto:nbeety@netzero.net]
Sent: Monday, January 10, 2011 9:11 PM
To: 100-District 1 831) 647-7991; 100-District 2 831) 755-5022; 100-District 3 831) 385-8333; 100-District 4
831) 883-7570; 100-District 5 831) 647-7755
Cc: nbeety@netzero.net
Subject: Smart Meter report, #38 consent agenda
January 10, 2011
Re: Consent Agenda Item #38: Health Department Report on PG&E Smart Meters
To the Monterey County Board of Supervisors:
Last Tuesday, Marin County Board of Supervisors passed an urgency ordinance halting the installation
of Smart Meters and infrastructure in the county. The ordinance is attached.
Tomorrow, the Santa Cruz Board of Supervisors will vote on an urgency ordinance, introduced by two
supervisors, which renews and strengthens the moratorium on Smart Meters and infrastructure they had
in place until Dec. 31. Also tomorrow, Lake County Board of Supervisors will be discussing a request
for a moratorium on Smart Meters. San Luis Obispo County will be taking up this issue at a future
meeting; a supervisor at the last meeting stated that his PG&E bill doubled after a Smart Meter was
installed.
I request that you reject the Health Department report on Smart Meters.
1/11/2011
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PUBLIC COMMENT�T��"�|E��j��Page 2 of 4
Since June, I have presented the Monterey County Board of Supervisors and the Health Department
with substantial and ongoing information and documentation concerning the many problems with Smart
Meters, including but not limited to the RF safety issues.
However, after an almost 5 month official investigation, the conclusion of the Health Department
appears to bypass all this information in favor of information from PG&E.
I think there is some confusion. PG&E is a for-profit commercial entity. It is not a public agency in any
way. It sells products electricity and natural gas to the public.
In addition, PG&E is a company with a very checkered history on safety, honesty, and admission of
responsibility.
As I stated in a previous letter, the Division of Ratepayer Advocates called PG&E information regarding
safety evidence about RF emissions and the safety of Smart Meters weak", unreliable", disputed",
and inadequate". The DRA said: The Commission should... give serious consideration to
investigating the health concerns raised by EMF Safety) Network and other groups." I've attached the
application for rehearing filed by EMF Safety Network.
Regarding the Monterey County Health Department report:
These meters are one million microwatt meters, with a range that can exceed two miles, and Silver
Spring claims that their signal can go through mountains yet PG&E claims they can't be felt inside a
house). I have sent you and the Health Department charts showing just how potent tiny fractions of one
microwatt can be.
Furthermore, PG&E has not disclosed the normal strength of the peak power pulses emitted by its Smart
Meters. However, PG&E representatives have said, we all use the same meters, and Southern California
Edison has disclosed that the normal strength of the peak pulse is 155,600 microwatts. Cell phones do
not emit bursts of 155,600 microwatts, nor do they emit around the clock, 7 days a week. Furthermore,
PG&E's figures are time-averaged, not actual numbers, and are for one meter in isolation, not in a mesh
network relaying off each other or part of a bank of meters.
The FCC
has exposure guidelines voluntary; it does not have safety standards or limits,
aggressively promotes the industry it is entrusted with regulating,
has repeatedly been urged to revise guidelines because of their inadequacy, by agencies such
as the EPA, public advocacy groups, and the public, and
has guidelines that are far more lax than other countries; in some, these Smart Meters would
be illegal, even on the basis of Richard Tell's time-averaged figures.
However, the brand new report by Cindy Sage, which is attached, shows that Smart Meters can even
exceed FCC guidelines.
I have requested from the Health Department the list of scientists with whom they discussed Smart
Meters and a list of literature reviewed to come to their conclusion. What I have received so far is a
letter from Michael Herz, PG&E's EMF Program, with statements from the World Health Organization.
1/11/2011
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PUBLIC COMMENT�T��"�|E��l��Page 3 of 4
PG&E frequently cites the World Health Organization. I sent the Health Department evidence of World
Health Organization conflicts-of-interest due to industry involvement in creating their recommendations.
I would be happy to send you and them more information.
The World Health Organization
was chastised by the medical journal Lancet for routinely neglecting evidence, and
their EMF Task Force
o was funded in part by telecommunications contributions; contributions by the utility
companies, if any, and the total extent of industry contributions are unknown, because
they won't open the books,
o was chaired by an industry consultant, Michael Repacholi, and
o his assistant was an employee of the industry's Electric Power Research Institute. Her
name: Leeka Kheifets. There is an extensive history on her conflicts of interests working
for EPRI, ICNIRP another international advisory group), PG&E, and the CPUC during
which time she requested her financial records be sealed). She is also a professor at
UCLA.
o had consultations and assistance from industry in drafting and finalizing
recommendations for the public.
I requested that County Health Department staff attend the Commonwealth Club forum in November on
Health Effects of Electromagnetic Fields" with international scientists presenting data. Did anyone
from the county attend?
As regards the Structure Group report, there are serious questions about the Structure Group's
independence and the accuracy of the report. Attached is an article from the Bakersfield Californian, as
well as an excerpt from their report.
PG&E information" meetings to educate" and assure concerned citizens" are sales pitches; they are
not information from an independent public advocacy group. The information PG&E provides, either
through their information" meetings or in print, may be true or it may not be, and must be evaluated
carefully. As with anything for sale, it is a case of buyer beware."
Why are they so intent on rolling out the Smart Grid and Meters over vocal and growing opposition and
the substantial problems?
It appears that PG&E and other utility companies will make a great deal of money on other uses for their
Smart Meters and Smart Grid, including city-wide Wi-Fi. This is showing up in a myriad of newspaper
accounts across the country. Last weekend in Las Vegas was a summit at the Consumer Electronics
Show to discuss Smart Grid opportunities." These meters will not just be firing with energy data.
Electric and gas income will probably be incidental compared to the sums they will earn in leasing out
the network, rendering all their statistics about transmit times a complete fiction.
This is a huge gamble, because the public might catch on. PG&E is working faster and faster to stay
ahead of the growing uproar.
1/11/2011
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PUBLIC COMMENT�T��"�|E��n��Page 4 of 4
What did Watsonville, Fairfax, and Santa Cruz and Marin Counties do? They adopted ordinances
halting these meters and their infrastructure.
Again, I request that you reject this report from the Health Department. And I further request that you
agendize consideration of an urgency ordinance at the very earliest date possible that not only halts the
installation of Smart Meters and their infrastructure, but also deactivates already installed Smart Meters
and infrastructure.
Sincerely,
Nina Beety
277 Mar Vista Dr.
Monterey, CA 93940
nbeety@netzero.net
Attached:
Marin County Smart Meter ordinance
EMF Safety Network Application for Rehearing to the CPUC
Cindy Sage Declaration and Report charts at http://sagereports.com/smart-meter-rf/)
Bakersfield Californian article on Structure Group
Structure Group Report excerpt
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PUBLIC COMMENT�T��"�|E��o�� NOTEXTPAGE
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PUBLIC COMMENT�T��"�|E��p��ORDINANCE NO. 3552
AN UNCODIFIED ORDINANCE OF THE BOARD OF SUPERVISORS OF THE COUNTY OF
MARIN ADOPTED AS AN URGENCY MEASURE IMPOSING A TEMPORARY
MORATORIUM ON THE INSTALLATION OF SMARTMETERS AND RELATED EQUIPMENT
IN, ALONG, ACROSS, UPON, UNDER AND OVER THE PUBLIC STREETS AND OTHER
PLACES WITHIN THE UNINCORPORATED AREA OF MARIN COUNTY
THE BOARD OF SUPERVISORS OF THE COUNTY OF MARIN FIND AS FOLLOWS:
WHEREAS, the County of Marin the County"), through its police powers granted by
Article XI of the California Constitution, retains broad discretion to legislate for public purposes
and for the general welfare, including but not limited to matters of public health, safety and
consumer protection; and
WHEREAS, the County of Marin has a franchise agreement with PG&E that has been
in effect since the early 1950's; and
WHEREAS, in addition, the County retains authority under Article XII, Section 8 of the
Constitution to grant franchises for public utilities, and pursuant to California Public Utilities
Code section 6203, may in such a franchise impose such other and additional terms and
conditions..., whether governmental or contractual in character, as in the judgment of the
legislative body are to the public interest;" and
WHEREAS, Public Utilities Code section 2902 reserves the County's right to supervise
and regulate public utilities in matters affecting the health, convenience and safety of the
general public, such as the use and repair of public streets by any public utility, the location of
the poles, wires, mains, or conduits of any public utility, on, under, or above any public streets,
and the speed of common carriers operating within the limits of the municipal corporation;" and
WHEREAS, Pacific Gas & Electric Company PG&E") is now installing SmartMeters
in Central and Northern California and is installing these meters within the County of Marin; and
WHEREAS, concerns about the impact and accuracy of SmartMeters have been
raised nationwide, leading the Maryland Public Service Commission to deny permission on June
21, 2010. for the deployment of SmartMeters in that state. The State of Hawaii Public Utility
Commission also recently declined to adopt a smart grid system in that state. The CPUC
recently had before it a petition from the City and County of San Francisco, and other
municipalities, seeking to delay the implementation of SmartMeters until the questions about
their accuracy can be evaluated; and
WHEREAS, major problems and deficiencies with SmartMeters in California have
been brought to the attention of the Board of Supervisors of the County of Marin, including
PG&E's confirmation that SmartMeters have provided incorrect readings costing ratepayers
untold thousands of dollars in overcharges and PG&E's records outlined risks" and issues"
including an ongoing inability to recover real-time data because of faulty hardware originating
with PG&E vendors; and
WHEREAS, the ebb and flow of gas and electricity into homes discloses detailed
information about private details of daily life. Energy usage data, measured moment by
moment, allows the reconstruction of a household's activities: when people wake up, when they
Ordinance No. 3552
Page 1 of 4
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PUBLIC COMMENT�T��"�|E��q��come home, when they go on vacation, and even when they take a hot bath. SmartMeters
represent a new form of technology that relays detailed hitherto confidential information
reflecting the times and amounts of the use of electrical power without adequately protecting
that data from being accessed by unauthorized persons or entities and as such pose an
unreasonable intrusion of utility customers' privacy rights and security interests. Indeed., the
fact that the CPUC has not established safeguards for privacy in its regulatory approvals may
violate the principles set forth by the U.S. Supreme Court in Kyllo v. United States 2001), 533
U.S. 27; and
WHEREAS, there is now evidence showing that problems with SmartMeters could
adversely impact the amateur radio communication network that operates throughout California
and neighboring states, as well as other radio emergency communication systems that serve
first responders, government agencies, and the public; and
WHEREAS, significant health questions have been raised concerning the increased
electromagnetic frequency radiation EMF) emitted by the wireless technology in SmartMeters,
which will be in every house, apartment and business, thereby adding additional man-made
EMF to our environment around the clock to the already existing EMF from utility poles,
individual meters and telephone poles; and
WHEREAS, FCC safety standards do not exist for chronic long-term exposure to EMF
or from multiple sources, and reported adverse health effects from electromagnetic pollution
include sleep disorders, irritability, short term memory loss, headaches, anxiety, nausea, DNA
breaks, abnormal cell growth, cancer, premature aging, etc. Because of untested technology,
international scientists, environmental agencies, advocacy groups and doctors are calling for the
use of caution in wireless technologies; and
WHEREAS, the primary justification given for the SmartMeters program is the
assertion that it will encourage customers to move some of their electricity usage from daytime
to evening hours; however, PG&E has conducted no actual pilot projects to determine whether
this assumption is in fact correct. Non-transmitting time-of-day meters are already available for
customers who.desire them, and enhanced customer education is a viable non-technological
alternative to encourage electricity use timeshifting. Further, some engineers and energy
conservation experts believe that the SmartMeters program in totality could well actually
increase total electricity consumption and therefore the carbon footprint; and
WHEREAS, Assembly member Jared Huffman has requested the California Council
on Science and Technology to advise him on whether the Federal Communications
Commission's standards for SmartMeters are sufficiently protective and assess whether
additional technology-specific standards are needed for SmartMeters; and
WHEREAS, a response to Assembly member Huffman from the Council on Science
and Technology is expected in the near future; and
WHEREAS, Assembly Member Huffman has also recently introduced legislation AB
37) which would add a section to the Public Utilities Code to require the CPUC to identify
alternative options for customers who do not wish to have a wireless SmartMeter installed and
allow customers to opt-out of wireless SmartMeter installation, including removing existing
SmartMeters where requested by the customer. Most importantly, the legislation would
suspend deployment of SmartMeters until the CPUC meets the above requirements; and
Ordinance No. 3552
Page 2 of 4
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PUBLIC COMMENT�T��"�|E��r��WHEREAS, this Board of Supervisors has sent letters to the President of the CPUC
on July 20, 2010 and again on October 26, 2010 asking that the CPUC suspend PG&E's
authority to deploy SmartMeters or related equipment in Marin County until certain reports now
in process have been completed and reviewed and considered, and certain other conditions
have been met; and
WHEREAS, there has been no response to either of these letters; and
WHEREAS, because the potential risks to the health, safety and welfare of County
residents are so great, the Board of Supervisors wishes to adopt a moratorium on the
installation of SmartMeters and related equipment within the unincorporated area of the County
of Marin. The moratorium period will allow the Council on Science and Technology and
legislative process. referenced above to be completed and for additional information to be
collected and analyzed regarding potential problems with SmartMeters; and
WHEREAS, there is a current and immediate threat to public health, safety and
welfare because, without this urgency ordinance, SmartMeters or supporting equipment will be
installed or constructed or modified in the County without PG&E's complying with the CPUC
process for consultation with the local jurisdiction, the County's Code requirements, and
subjecting residents of Marin County to the privacy, security, health, accuracy and consumer
fraud risks of the unproven SmartMeter technology; and
WHEREAS, the Board of Supervisors hereby finds that it can be seen with certainty
that there is no possibility that the adoption and implementation of this Ordinance may have a
significant effect on the environment. This Ordinance does not authorize construction or
installation of any facilities and, in fact, imposes greater restrictions on such construction and
installation in order to protect the public health, safety and general welfare. This Ordinance is
therefore exempt from the environmental review requirements of the California Environmental
Quality Act CEQA) pursuant to Section 15061(b)(3) of Title 14 of the California Code of
Regulations; and
WHEREAS, there is no feasible alternative to satisfactorily study the potential impact
identified above as well or better with a less burdensome or restrictive effect than the adoption
of this interim urgency moratorium ordinance; and
WHEREAS, based on the foregoing it is in the best interest of public health, safety and
welfare to allow adequate study of the impacts resulting from the SmartMeter technology;
therefore it is appropriate to adopt a temporary moratorium that would remain in effect from the
date of its adoption until December 31, 2011, unless your Board acts to repeal it prior to that
date.
NOW, THEREFORE, BE IT ORDAINED by the Board of Supervisors of the County of
Marin as follows:
SECTION I
Moratorium. From and after the effective date of this Ordinance, no SmartMeter may
be installed in or on any home, apartment, condominium or business of any type within the
unincorporated area of the County of Marin, and no equipment related to SmartMeters may be
installed in, on, under, or above any public street or public right of way within the unincorporated
area of the County of Marin.
Ordinance No. 3552
Page 3 of 4
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PUBLIC COMMENT�T��"�|E��s��SECTION II
Violations of the Moratorium may be charged as infractions or misdemeanors as set
forth in Section 1.04.270 of the Marin County Code. In addition, violations shall be deemed
public nuisances, with enforcement by injunction or any other remedy authorized by law,
SECTION III
This Board of Supervisors finds and determines that: a) there is a current and
immediate threat to the public peace, health, or safety; b) the moratorium must be imposed in
order to protect and preserve the public interest, health, safety, comfort and convenience and to
preserve the public welfare; and c) it is necessary to preserve the public health and safety of all
residents or landowners adjacent to such uses as are affected by this interim ordinance as well
as to protect all of the citizens of Marin County by preserving and improving the aesthetic and
economic conditions of the County.
SECTION IV
If any provision of this interim ordinance is held to be unconstitutional, it is the intent of
the Board of Supervisors that such portions of such ordinance be severable from the remainder
and the remainder be given full force and effect.
SECTION V
This interim ordinance is not subject to the California Environmental Quality Act
CEQA) pursuant to Section 15060(c) 2) the activity will not result in. a direct or reasonably
foreseeable indirect physical change in the environment and Section 15060(c) 3) the
activity is not a project as defined in Section 15378 of the CEQA Guidelines, because it has no
potential for resulting in physical change to the environment, directly or indirectly.
SECTION VI
Effective Dates. This ordinance shall take effect immediately based on the findings by
the Board of Supervisors that this ordinance is necessary for the protection of the public health,
safety, and general welfare. This ordinance shall be in full force and effect from the date of its
adoption by the Board of Supervisors until December 31, 2011, at which time its terms and
provisions shall expire and no longer remain in effect.
PASSED AND ADOPTED at a regular meeting of the Board of Supervisors of the
County of Maria held on this 4th day of January 2011 by the following vote:
AYES: SUPERVISORS Judy Arnold, Charles McGlashan, Steve Kinsey, Susan Adams
NOES: NONE
ABSENT: SUPERVISOR Harold C. Brown, Jr.
Ordinance No. 3552
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PUBLIC COMMENT�T��"�|E��t��BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
Application of EMF Safety Network for Modification
of D.06-07-027 and D.09-03-026.
Application 10-04-018
Filed April 6, 2010)
APPLICATION OF EMF SAFETY NETWORK
FOR REHEARING OF DECISION 10-12-001
January 5, 2011
Sandra Maurer, Founder
EMF Safety Network
PO Box 1016
Sebastopol CA 95473
Tel. 707) 824-0824
sandi@emfsafetynetwork.org
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PUBLIC COMMENT�T��"�|E��u��A.10-04-018 EMF Safety Network
TABLE OF CONTENTS
1. Introduction and Summary 1
2. Background 3
3. Standard of Review 3
4. Legal, Technical and Factual Errors 4
4.1. The Commission Has a Responsibility to Ensure and Protect Public
Safety 4
4.2. The Commission Wrongly Defers to the FCC 5
4.3. The Commission Has Previously Investigated EMF and RF Health
Impacts 6
4.4. The Commission Has a Mandate to Reduce EMF 8
4.5. Smart Meters Violate FCC Safety Regulations 8
4.6. The Commission Decision to Mandate Smart Meters Violates State and
Local Laws 9
4.7. General Order 168, Consumer Bill of Rights 10
4.8. General Order 159A, Mobile Services Facilities Rules 12
4.9. The Commission Must Address Serious Public Concerns 12
5. Conclusion 13
Declaration of Sandra Maurer
Declaration of Cynthia Sage
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PUBLIC COMMENT�T��"�|E��v��A.10-04-018 EMF Safety Network
TABLE OF AUTHORITIES
California Constitution
Article 1, Declarations of Rights Section 1 9
Article 1, Declarations of Rights Section 4 10
Article XII, Section 6 6
Public Utilities Code
Section 451 4, 6, 7
Section 701 6
Section 761 4
Section 762 4
Section 768 4
Section 1001 7
Section 1002 6, 7
Section 1757 3
Health and Safety Code
Section 120365 10
Commission Orders
Investigation 91-01-012 6
D.95-11-017 1,6,7
D.06-01-042 8
Commission General Orders
General Order 159A, Rules Relating to the Construction of Commercial
Mobile Radio Service Facilities in California
2,
12
General Order 168, Rules Governing Telecommunications Consumer
Protection
2,
11
Commission Rules
Rule 16.1 1,3
Rule 16.4(b) 13
Federal Law
National Environmental Policy Act of 1969 7
Telegraphs, Telephones, and Radiotelegraphs,
47 U.S.C. 332 c)(7)(b)(iv) 10
iii
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PUBLIC COMMENT�T��"�|E��w��A.10-04-018 EMF Safety Network
Court Cases
SDG&E v Covalt 1996) 13 Cal. 4th 893 6
PG&E Corp v CPUC 2004) 118 Cal. App. 4th 1174, 1198 6
City of Sebastopol Ordinance
Chapter 17, Section 17.100.010 9
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PUBLIC COMMENT�T��"�|E��x��A.10-04-018 EMF Safety Network
APPLICATION OF EMF SAFETY NETWORK
FOR REHEARING OF DECISION 10-12-001
1. Introduction and Summary
On December 2, 2010, the Commission signed Decision D.) 10-12-001, which
dismissed the application of EMF Safety Network Network) for modification of
D.06-07-027 and D.09-03-026, in which the Commission approved installation of Smart
Meters by Pacific Gas and Electric Company PG&E). The Commission mailed
D.10-12-001 to parties of record on December 6, 2010.
Pursuant to Rule 16.1 of the Commission's Rules of Practice and Procedure',
Network submits this application for rehearing of D.10-12-001. The due date for
applications for rehearing is January 5, 2011. Network will file this pleading
electronically on the due date.
The Commission has an obligation to ensure safe delivery of gas and electric
service and has committed legal error by neglecting and deferring its utility regulation
duties to the Federal Communications Commission FCC). This Commission, not the
FCC, mandated Smart Meters in the California. The Commission previously
investigated the heath impacts of radio frequency radiation RF) emissions. In
D.95-11-017, the Commission recognized public perception of harm, warned that
financial interests should not trump health impacts, and ordered follow-up workshops on
the subject. The basis for these outcomes was the possibility that a public health
hazard could exist.
In 2006 the Commission upheld a mandate to carry out no and low cost
electromagnetic field EMF) reduction measures. However, the Commission failed to
follow its own precautionary mandate by allowing PG&E and other utilities throughout
California to deploy RF Smart Meters.
The Commission's decision to dismiss Network's application relies heavily on
1 Rule 16.1 provides that an application for rehearing shall be filed within 30 days after
the date the Commission mails the order or decision.
1
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PUBLIC COMMENT�T��"�|E��y��A.10-04-018 EMF Safety Network
PG&E's unsubstantiated claim that the RF emissions 10 feet away from a Smart Meter
are 1/6000 of the federal standard. Network asserts that a single RF number cannot
adequately describe RF exposure, due to variations in duty cycles, reflections and
number of meters in the vicinity. Network provides a declaration based on a study that
includes evidence of violations of the FCC standard. Network further alleges that Smart
Meters in the manner deployed violate one or more conditions for FCC compliance.
Network provides a declaration supporting these assertions.
The mandatory installation of radiation-emitting Smart Meters violates basic
rights granted by the State of California, overburdens utility easements and violates
local laws. Network asserts its legal right to practice prudent avoidance of EMF and RF
devices, which the State of California advocates.
Although Network does not believe or support PG&E's position that Smart Meters
are personal wireless service facilities", if the Commission agrees with PG&E than we
submit that General Order 168, Rules Governing Telecommunications Consumer
Protection, applies to Smart Meters. The Consumer Bill of Rights in General Order 168
require consumer choice of vendor, full product disclosure, privacy, accurate bills, and
the right to safety and security of their persons and property. Network also refers to
General Order 159A, which addresses construction rules for mobile service facilities.
The Commission has a civic responsibility to address serious allegations of
public health, safety and environmental impacts from RF Smart Meters. The
Commission should respond to requests for a Smart Meter moratorium submitted by
thousands of people, including local jurisdictions. Considering the enormity of the RF
project statewide, the Commission should not bury its head in the sand by rejecting
Network's application. Dismissal of the application was a wrong that must be righted.
The Commission should reopen its review of Smart Meters, order an immediate
moratorium on the deployment of Smart Meters, hold public evidentiary hearings, offer
shielded wire alternatives or maintain existing electromechanical meters to ensure that
the Smart Meter program is consistent with delivery of safe, gas and electric service.
Network requests rehearing of its application for modification of D.06-07-027 and
D.09-03-026.
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PUBLIC COMMENT�T��"�|E��z��Radiation Emissions from Smart Meters to document radiofrequency radiation
RF) levels associated with wireless smart meters in various scenarios depicting
common ways in which they are installed and operated.
5. The Report includes computer modeling of the range of possible smart meter RF
levels that are occurring in the typical installation and operation of a single smart meter,
and also multiple meters in California.
6. FCC compliance violations are likely to occur under normal conditions of
installation and operation of smart meters and collector meters in California, because
the public has access to smart meters installed on their homes.
7. In addition to exceeding FCC public safety limits under some conditions of
installation and operation, smart meters can produce excessively elevated RF
exposures, depending on where they are installed. RF levels are predicted to be
substantially elevated within a few feet to within a few tens of feet from the meter(s).
9. RF levels associated with smart meters under some conditions of installation and
operation will produce RF power density levels that exceed those reported in some
scientific studies to result in adverse health impacts, including headache, sleep
disruption, restlessness, tremor, cognitive impairment, tinnitus, increased cancer risk,
and cardiac problems at distances less than 500 meters from cell antennas, or at levels
over 0.1 microwatts per centimeter squared. 1.2.3.4.5.6
10. 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.
11. People who are afforded special protection under the federal Americans with
Disabilities Act are not sufficiently acknowledged nor protected. People who have
medical and/or metal implants or other conditions rendering them vulnerable to health
risks at lower levels than FCC RF limits may be particularly at risk.
1 http://sagereports.com/smart-meter-rf/
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PUBLIC COMMENT�T��"�|E��{�� NOTEXTPAGE
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PUBLIC COMMENT�T��"�|E��|��A.10-04-018 EMF Safety Network
2. Background
In D.10-12-001 the Commission granted the motion of PG&E to dismiss the
application of the EMF Safety Network for modification of D.06-07-027 and D.09-03-
026. The Decision Summary states that RF emissions from Smart Meters are 1/6000 of
the Federal standard at 10 feet from a Smart Meter.2 In its discussion the Commission
deferred its responsibility to the FCC then concluded that it was not reasonable to
reopen a review of Smart Meters based on alleged heath impacts.3
In the application, Network alleged that the RF from Smart Meters poses serious
public health, safety and environmental impacts.' Network challenged PG&E's
inconsistent and unreliable claims. Network stated it did not ask for regulation of RF by
the Commission.' Network asked for an independently prepared RF Emissions Study;
public hearings on RF health, environmental, and safety impacts; review of actual Smart
Meter program performance; authorization for customers to opt out of Smart Meter
installation; and an immediate moratorium on PG&E Smart Meters.' These requests
and allegations of harm are backed by substantial peer-reviewed science, anecdotal
evidence, and widespread community expressions of concern.
3. Standard of Review
Public Utilities Code Section 1757 provides that, when a court reviews the validity
of a Commission decision, it considers, among other things, whether the findings in the
decision of the commission are not supported by substantial evidence in light of the
whole record." Rule 16.1 of the Commission's Rules of Practice and Procedure directs
applicants for rehearing to set forth specifically the grounds on which the applicant
considers the order or decision of the Commission to be unlawful or erroneous."
2 D.10-12-001, p. 1.
3 D.10-12-001, pp. 9, 15.
4 D.10-12-001, p. 14, Finding of Fact 1.
5 D.10-12-001, p. 5.
6 Application, p. 2.
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PUBLIC COMMENT�T��"�|E��}��A.10-04-018 EMF Safety Network
4. Legal, Technical and Factual Errors
4.1 The Commission Has a Responsibility to Ensure and Protect Public
Safety
The Commission has the primary authority and responsibility to protect the health
and safety of California ratepayers by ensuring that gas and electric utility service is
safe and reliable. See Public Utilities Code 451', 7618, 7629, and 76810.
451 Just and reasonable charges; Service; Rules) provides in relevant part: Every public
utility shall furnish and maintain such adequate, efficient, just, and reasonable service,
instrumentalities, equipment, and facilities, including telephone facilities, as defined in Section
54.1 of the Civil Code, as are necessary to promote the safety, health, comfort, and
convenience of its patrons, employees, and the public. All rules made by a public utility
affecting or pertaining to its charges or service to the public shall be just and reasonable."
B 761 Authority to regulate by order or rule following finding of unjust, unsafe, or inadequate
practices; Requirement of compliance) provides: Whenever the commission, after a
hearing, finds that the rules, practices, equipment, appliances, facilities, or service of
any public utility, or the methods of manufacture, distribution, transmission, storage, or
supply employed by it, are unjust, unreasonable, unsafe, improper, inadequate, or
insufficient, the commission shall determine and, by order or rule, fix the rules,
practices, equipment, appliances, facilities, service, or methods to be observed,
furnished, constructed, enforced, or employed. The commission shall prescribe rules
for the performance of any service or the furnishing of any commodity of the character
furnished or supplied by any public utility, and, on proper demand and tender of rates,
such public utility shall furnish such commodity or render such service within the time
and upon the conditions provided in such rules." Emphasis added.)
9 762 Authority to require changes in physical property of public utilities) provides in
relevant part: Whenever the commission, after a hearing, finds that additions,
extensions, repairs, or improvements to, or changes in, the existing plant, equipment,
apparatus, facilities, or other physical property of any public utility or of any two or more
public utilities ought reasonably to be made, or that new structures should be erected,
to promote the security or convenience of its employees or the public, or in any
other way to secure adequate service or facilities, the commission shall make and
serve an order directing that such additions, extensions, repairs, improvements, or
changes be made or such structures be erected in the manner and within the time
specified in the order." Emphasis added.)
10 768 Authority to direct use of safety devices) provides in relevant part: The
commission may, after a hearing, require every public utility to construct, maintain, and
operate its line, plant, system, equipment, apparatus, tracks, and premises in a manner
so as to promote and safeguard the health and safety of its employees,
passengers, customers, and the public." Emphasis added.)
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PUBLIC COMMENT�T��"�|E��~��A.10-04-018 EMF Safety Network
4.2 The Commission Wrongly Defers to the FCC
The Commission commits legal error by deferring its responsibility for the
deployment of Smart Meters to the FCC. The Decision defers to the FCC, stating, The
Commission generally does not delve into technical matters which fall within the
expertise of another agency, in this case, the FCC."11
Commission President and Assigned Commissioner Michael Peevey clearly
makes the case for deferral to the FCC in his statements regarding dismissal of
Network's Application12. At the Commission's December 2 public meeting, Peevey
stated, I believe that relying on the FCC in this case is reasonable, prudent and fully
consistent with our responsibilities to provide safe and reliable electric service to
ratepayers. We're relying on the federal agency in this regard." Commissioner Peevey
concluded his statements by telling the audience at the hearing, You should take these
concerns to the FCC, it's the proper body."
Although the Conclusions of Law in D.10-12-001 13 only mention reasonableness
generally, Commissioner Peevey made it clear that deferring to the FCC was the
primary reason for dismissal.
The Commission, not the FCC, mandated RF Smart Meters in California. It is the
responsibility of the Commission to serve the public interest by protecting consumers
and ensuring the provision of safe, reliable utility service and infrastructure at
reasonable rates, with a commitment to environmental enhancement and a healthy
California economy."14
The Division of Ratepayers Advocates DRA) concurs with Network about
Commission responsibility, stating, The FCC's authority to regulate RF emissions does
not deprive this Commission of its authority under state law to ensure that the in-state
11
D10-12-001, p. 9, Section 4.3
CPUC meeting Archive video http://www.californiaadmin.com/cpuc.shtml
D.10-12-001, p. 15.
CPUC home page: http://www.cpuc.ca.gov/puc/
12
13
14
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PUBLIC COMMENT�T��"�|E����A.10-04-018 EMF Safety Network
utility infrastructure does not jeopardize public health and welfare. As the appellate
courts have consistently recognized and recently reiterated, this Commission's authority
in this area is very broad. See, e.g., SDG&E v. Covalt 1996), 13 Cal. 4th 893; PG&E
Corp. v. CPUC 2004) 118 Cal. App. 4th 1174, 1198 Section 701 of the Public Utilities
Code allows the PUC to do all things necessary and convenient' in the exercise of
its authority over public utilities whether or not specifically designated' in the Public
Utilities Code. Where the authority sought is cognate and germane' to utility regulation,
the PUC's authority under section 701 has been liberally construed citations
omitted].)"15
4.3 The Commission Has Previously Investigated EMF and RF Health
Impacts
In 1991, Commission Order Instituting Investigation 91-01-012, the Statement of
Scope includes, With this order, the Commission begins an investigation of its potential
role in mitigating possible health effects of electric and magnetic fields created by
electric utility power systems, or in mitigating possible health effects from fields emitted
by cellular radiotelephone towers."16 This investigation led to a Commission mandate to
adopt EMF reduction measures. See Section 4.4 below.)
Decision 95-11-017, which followed the investigation, states, This order
addresses the cellular phase of our EMF investigation, which considers the
Commission's role in mitigating health effects, if any, of RF radiation generated by
cellular utilities within the Commission's jurisdiction. Article XII, Section 6 of the
California Constitution empowers the Commission to establish rules for the utilities it
regulates.17 Public Utilities Code Sections 451 and 1002 require the Commission to
consider the impact of utilities' services on the environment and human health and
15 DRA Comments p.4 http://docs.cpuc.ca.gov/efile/CM/126712.pdf
16 http://www.cpuc.ca.gov/Environment/emf/emfopen.htm
17 The commission may fix rates, establish rules, examine records, issue subpenas,
administer oaths, take testimony, punish for contempt, and prescribe a uniform system
of accounts for all public utilities subject to its jurisdiction."
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PUBLIC COMMENT�T��"�|E�����A.10-04-018 EMF Safety Network
safety. 18 CACD Commission Advisory and Compliance Division] shall hold informal
cellular EMF and RF radiation workshops as additional health information becomes
available and upon preparation of any updated EMF reports, and shall report the results
of such workshops to the Commission through the resolution process.19"20
In D.95-11-017, Appendix A, Section C, Issues for Future Consideration,
Issue #3, Public Perception of the Problem, states in part, The economic
considerations of this issue are significant. CACD raises the equally, if not more,
important issue of health and safety of the public. Public Utilities Code Section 451
requires regulated utilities to furnish and maintain facilities as necessary to promote the
health and safety of its patrons, employees and the public. Furthermore, Section 1002
requires the Commission, in granting any certificate, to consider the potential effects of
the project on community values and on the environment. The Commission is clearly
responsible for ensuring that the utilities it regulates are providing service and facilities
that do not constitute a threat to the public or the environment. As mentioned earlier,
the current research on the matter has left many questions unanswered and therefore
difficult to conclude that a health and safety problem does or does not exist. Until
clearer answers emerge, the Commission should consider the possibilities that a health
hazard could exist and that careful monitoring as well as some interim measures would
18 PU Code Section 1002, a) The commission, as a basis for granting any certificate
pursuant to Section 1001 shall give consideration to the following factors: 1)
Community values.(2) Recreational and park areas.(3) Historical and aesthetic values.
4) Influence on environment, except that in the case of any line, plant, or system or
extension thereof located in another state which will be subject to environmental impact
review pursuant to the National Environmental Policy Act of 1969 Chapter 55
commencing with Section 4321) of Title 42 of the United States Code) or similar state
laws in the other state, the commission shall not consider influence on the environment
unless any emissions or discharges there from would have a significant influence on the
environment of this state."
19 D.95-11-017, Ordering Paragraph 2.
20 D.95-11-017 is not directly available on the Commission's web site. See 1995 Cal.
PUC LEXIS 842; 165 P.U.R.4th 403. The document can be found at the web address
in footnote 16 herein.
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PUBLIC COMMENT�T��"�|E�����A.10-04-018 EMF Safety Network
be appropriate." The Commission explicitly adopted the language in this appendix.21
4.4 The Commission Has a Mandate to Reduce EMF
The California EMF Program Short Factsheet on EMF states, In 1993, the
California Public Utilities Commission CPUC) authorized the state's investor-owned
utilities to carry out no and low cost EMF avoidance and measures' in construction of
new and upgraded utility projects." A report of the history behind this authorization
states, On January 15, 1991, the PUC began an investigation to consider the
Commission's potential role in mitigating health effects, if any, of EMFs created by
electric utility power lines and by cellular radiotelephone facilities."22 In D.06-01-042,
issued in 2006, the Commission again ordered electric utilities to implement
low-cost/no-cost EMF mitigation measures, which affirmed the 1993 policy.23 The
Commission clearly recognized public concern and mandates EMF reduction measures
in the State of California. The Commission should apply the same precautionary
approach to Smart Meters.
4.5 Smart Meters Violate FCC Safety Regulations
PG&E has based its RF health and safety claims on their assertions that Smart
Meters comply with all FCC regulations. In D.10-12-001 the Commission upheld-
without question or investigation PG&E's unproven claims. The Commission wrongly
accepted PG&E's assessment of RF safety at ten feet from a single Smart Meter.
Multiple factors affect RF exposure in the environment, including duty cycle, reflections
and number of nearby meters. The Assessment of Radiofrequency Microwave
Radiation Emissions from Smart Meters"24 demonstrates that RF levels transmitted by
RF Smart Meters can violate FCC guidelines under normal conditions of installation and
operation. See attached Declaration of Cynthia Sage.
21 D.95-11-017, Ordering Paragraph 1.
22 Application, p. 8, footnote 7, citing PUC Actions Regarding EMFs;
http://www.cpuc.ca.gov/PUC/energy/Environment/ElectroMagnetic+Fields/action
23 D.06-01-042, p. 22, Ordering Paragraph 2.
24 Sage Associates, 2011, http://sagereports.com/smart-meter-rf/
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PUBLIC COMMENT�T��"�|E�����A.10-04-018 EMF Safety Network
Furthermore, the FCC Grants of Equipment Authorization, which govern the rules
upon which FCC compliance is based, warn that RF exposure compliance depends on
specific conditions. As stated in Network's reply comments to the proposed decision
that preceded D.10-12-001, Network further alleges that RF Smart Meters in the
manner deployed by PG&E violate one or more conditions for FCC compliance.25 See
also attached Declaration of Sandi Maurer. The CPUC must ensure the utilities adhere
to the necessary FCC conditions, within those Grants of Authorization.
4.6 The Commission Decision to Mandate Smart Meters Violates State
and Local Laws
The mandatory installation of radiation-emitting Smart Meters violates basic
rights granted by the State of California, overburdens utility easements and violates
local laws. The California Constitution, Article 1, Declaration of Rights, Section 1 states,
All people are by nature free and independent and have inalienable rights. Among
these are enjoying and defending life and liberty, acquiring, possessing, and protecting
property, and pursuing and obtaining safety, happiness, and privacy." Mandatory
installation of Smart Meters infringes on people's rights to protect their property, life and
liberty. The radiation emitted by Smart Meters is an environmental toxin which infringes
on people's rights to obtain safety. Existing utility franchise agreements generally lack
specific provisions regarding RF emissions. PG&E's installation of Smart Meters and
associated infrastructure goes far beyond the intentions of utility easements
incorporated into most if not all franchise agreements. Furthermore, standard
homeowner's insurance policies explicitly exclude RF damage from coverage, putting
ratepayers at risk for hazards not contemplated in utility franchise agreements. PG&E's
RF system violates at least one local wireless ordinance. For example, a City of
Sebastopol wireless facility ordinance26 requires that minor antennas cannot be installed
within 10 feet of power lines, cannot be installed on wood structures, and are limited to
25 Reply Comments of EMF Safety Network on Proposed Decision of ALJ Sullivan,"
November 22, 2010, pp. 1-3.
26 Chapter 17, General Provisions Relating to Telecommunications Facility and Minor
Antenna, Sections 17.100.010 A) through C).
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PUBLIC COMMENT�T��"�|E�����A.10-04-018 EMF Safety Network
six antennas in a single location. Smart Meters clearly contain minor antennas.
Network believes that EMF, and specifically RF emitted by Smart Meters, is a
hazard to be avoided because it is dangerous. Network believes the forced installation
of RF devices in our homes and cities is discrimination based on our beliefs and rights
to practice prudent avoidance of EMF, which the State of California advocates. The
California Constitution, Article 1, Declaration of Rights Section 4, states, Free exercise
and enjoyment of religion without discrimination or preference are guaranteed. This
liberty of conscience does not excuse acts that are licentious or inconsistent with the
peace or safety of the State. The Legislature shall make no law respecting an
establishment of religion One example of rights associated with personal beliefs is
the right to refuse immunization of schoolchildren.27
4.7 General Order 168, Consumer Bill of Rights
In its motion to dismiss the application, PG&E asserted Federal preemption.
PG&E implied that Smart Meters are personal wireless service facilities. PG&E quoted
this language pertaining to preemption, No state or local government or instrumentality
thereof may regulate the placement, construction and modifications of personal wireless
service facilities on the basis of the environmental effects of radio frequency emissions
to the extent that such facilities comply with the Commission's regulations concerning
such emissions."28
Network disputes Federal preemption, and Network does not believe that Smart
Meters are mobile services facilities. However, if the Commission accepts PG&E's
27 California Health and Safety Code, Section 120365. Immunization of a person shall
not be required for admission to a school or other institution if the parent or
guardian or adult who has assumed responsibility for his or her care and custody in
the case of a minor, or the person seeking admission if an emancipated minor, files
with the governing authority a letter or affidavit stating that the immunization is
contrary to his or her beliefs. However, whenever there is good cause to believe that
the person has been exposed to one of the communicable diseases listed in
subdivision a) of Section 120325, that person may be temporarily excluded from the
school or institution until the local health officer is satisfied that the person is no
longer at risk of developing the disease."
28 PGE Motion For Dismissal, p. 10, citing 47 U.S.C. 332 c)(7)(b)(iv).
10-
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position that Smart Meters are mobile services facilities, then Network submits that the
Commission's General Order 168,29 which includes a Consumer Bill of Rights, should
apply to Smart Meters. The Consumer Bill of Rights states, The Commission declares
that all consumers who interact with telecommunications providers must be afforded
certain basic rights, and those rights shall be respected by the Commission-regulated
providers with whom they do business." The Consumer Bill of Rights includes the
following directives:
Disclosure: Consumers have a right to receive clear and complete information
about rates, terms and conditions for available products and services, and to be
charged only according to the rates, terms and conditions they have agreed to.
Choice: Consumers have a right to select their services and vendors, and to
have those choices respected by the industry.
Privac Consumers have a right to personal privacy, to have protection from
unauthorized use of their records and personal information, and to reject intrusive
communications and technology.
Public Participation and Enforcement: Consumers have a right to participate in
public policy proceedings, to be informed of their rights and what agencies
enforce those rights, and to have effective recourse if their rights are violated.
Accurate Bills and Redress: Consumers have a right to accurate and
understandable bills for products and services they authorize, and to fair, prompt
and courteous redress for problems they encounter.
Non-Discrimination: Every consumer has the right to be treated equally to all
other similarly-situated consumers, free of prejudice or disadvantage.
Safety: Consumers have a right to safety and security of their persons and
property."
29 General Order 168, Rules Governing Telecommunications Consumer Protection.
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4.8 General Order 159A, Mobile Services Facilities Rules
PG&E Smart meters use RF technology in a microwave radio system that widely
exposes the public to an unprecedented increase in RF exposures. However, PG&E is
not a registered telecommunications provider.
The Commission's General Order 159A outlines rules for construction of mobile
radio services facilities in California. Network asserts that several of General
Order 159A goals remain unaddressed by the Commission's decision to dismiss
Network's application, including compliance with the California Environmental Quality
Act CEQA). General Order 159A requires that affected citizens, organizations and
local government are given reasonable notice and opportunity for input into the review
process" and that the public health, safety, welfare, and zoning concerns of local
government are addressed." Network asserts that the Commission must address these
considerations.
4.9 The Commission Must Address Serious Public Concerns
The Commission has received complaints from thousands of individual
ratepayers and tens of city and county jurisdictions, including, but not limited to: the
City and County of San Francisco; Santa Cruz County and Marin County Boards of
Supervisors; Sonoma County Supervisors Efren Carrillo and Shirley Zane; the cities of
Belvedere, Berkeley, Bolinas, Camp Meeker, Capitola, Cotati, Fairfax, Monte Sereno,
Morro Bay, Novato, Piedmont, Richmond, Ross, San Anselmo, San Clemente, San
Rafael, Santa Cruz, Sausalito, Scotts Valley, Sebastopol and Watsonville; the Peace
and Freedom Party; the Marin Association of Realtors; and the Sonoma County
Republican Central Committee. These organizations have called for a moratorium, a
ban, the right to opt out, or are opposing Smart Meters.
Considering the serious and growing community concern over Smart Meter
problems, including health, safety and environmental impacts from RF Smart Meters,
Network believes the Commission has a civic obligation to investigate this issue in a
public proceeding.
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PUBLIC COMMENT�T��"�|E�����A.10-04-018 EMF Safety Network
5. Conclusion
The Commission should reopen its review of Smart Meters, and provide relief to
Network and other jurisdictions by ordering an immediate moratorium on the
deployment of RF Smart Meters. The Commission should convene public evidentiary
hearings on health, safety and environmental impacts, in order to provide ratepayers
and interested parties an opportunity to ensure that Commission policies are consistent
with delivery of safe gas and electric service.
Rule 16.4(b) requires that allegations of new facts must be supported by a
declaration or affidavit. Network has researched FCC regulations and has reviewed
PG&E's compliance with FCC conditions. The Declaration of Sandra Maurer asserts
that FCC Grants of Equipment Authorization, which govern the rules upon which FCC
compliance is based, warn that RF exposure compliance depends on specific
conditions, and that PG&E Smart Meters violate one or more conditions for FCC
compliance. The Declaration of Cynthia Sage summarizes a report titled Assessment
of Radiofrequency Microwave Radiation Emissions from Smart Meters," which
demonstrates that RF levels transmitted by publicly accessible PG&E Smart Meters can
violate FCC guidelines under normal conditions of installation and operation.
Dated January 5, 2011, at Sebastopol, California.
/s/
Sandra Maurer, Founder
EMF Safety Network
PO Box 1016
Sebastopol CA 95473
Tel. 707) 824-0824
sand i@a emfsafetynetwork.org
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PUBLIC COMMENT�T��"�|E�����A.10-04-018 EMF Safety Network
Declaration of Sandra Maurer
I, Sandra Maurer, declare as follows:
1. I reside in Sebastopol, California. My mailing address is 200 Frankel Lane,
Sebastopol, California 95472.
2. I am a residential electric and gas customer of Pacific Gas and Electric Company
PG&E). I am aware that PG&E is currently installing Advanced Metering Infrastructure
gas and electric meters, known as Smart Meters, in Sonoma County and throughout
PG&E's service territory.
3. I am the founder of the EMF Safety Network Network), which is a coalition of
PG&E ratepayers, business and property owners, and concerned citizens in Northern
California who address health, environmental, and safety impacts associated with EMF
and RF technologies.
4. In its filings in Application 10-04-018, PG&E based its radio frequency radiation
RF) safety claims on their assertions that Smart Meters comply with all Federal
Communications Commission FCC) regulations. California Public Utilities Commission
Decision 10-12-001 relied on PG&E's unproven claims in its dismissal of Network's
application.
5. FCC Grants of Equipment Authorization, which govern the rules upon which FCC
compliance is based, warns that RF exposure compliance depends on specific
conditions.
6. Network has researched FCC conditions for the following meters that PG&E is
deploying: FCC ID numbers OWS-NIC514, OWS-NIC507, and LLB6327PWM.
7. Network believes that PG&E Smart Meters violate one or more FCC conditions
that determine RF exposure compliance. The conditions include one or more of the
following, depending on the specific make and model of Smart Meter:
limited single module approval requires professional installation;
antenna(s) must provide a separation distance of at least 20 centimeters
cm) from all persons;
1
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PUBLIC COMMENT�T��"�|E�����A.10-04-018 EMF Safety Network
antenna(s) must not be co-located or operating in conjunction with any
other antenna or transmitter;
end-users and installers must be provided with antenna installation and
transmitter operating conditions to satisfy RF exposure compliance.
8. I doubt that several weeks of installer training qualifies PG&E installers as
professionals" and also doubts that Smart Meter installers are given accurate
information about RF operating conditions.
9. Many PG&E Smart Meters are installed within 20 cm of public access. In some
cases the meters are installed inside homes and businesses. In many situations Smart
Meters are easily accessible to the public.
10. PG&E Smart Meters are widely co-located in banks of multiple meters.
Co-location also occurs within Smart Meters because electric Smart Meters include at
least two internal RF antennas. One antenna is used for the mesh network system and
the other is for Home Area Network HAN) systems. Antennas are designed to work in
conjunction with HAN and RF appliances and with other Smart Meters in a mesh
network.
11. Antennas have separate Grants of Equipment Authorization, which suggests that
manufacturers have tested antennas in isolation and individually, and not in
combination, which is how the Smart Meter and the Smart Grid system were designed
to operate.
12. Network believes that end users" are utility customers. PG&E has not provided
end users with antenna installation and transmitter operating conditions to satisfy RF
exposure compliance. FCC conditions that specify that end users are to have no
manual instructions to remove or install the device confirm Network's belief that the end
user is the customer.
13. Research into other Smart Meter Grants of Equipment Authorizations indicates
there are similar violations in other utility districts in California.
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PUBLIC COMMENT�T��"�|E�����A.10-04-018 EMF Safety Network
Under penalty of perjury, I declare that the facts set forth above are true and
correct to the best of my knowledge.
Dated January 5, 2011, at Sebastopol, California.
/s/
Sandra Maurer
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PUBLIC COMMENT�T��"�|E�����A.10-04-018 EMF Safety Network
Declaration of Cynthia Sage, Sage Associates
I, Cynthia Sage, declare as follows:
1. My name is Cynthia Sage. I am the owner of Sage Associates, an environmental
consulting firm. My business address is 1396 Danielson Road, Montecito, California,
93108. I am providing this declaration in support of Application 10-04-018.
2. I have been a professional environmental consultant since 1972. I hold an M.A.
degree in Geology, and a B.A. in Biology Zoology) from the University of California,
Santa Barbara. I am a Senior Fellow, Department of Oncology, School of Health and
Medical Sciences, Orebro University, Orebro, Sweden 2008-2011).
3. I served as a member of the California Public Utilities Commission CPUC) EMF
Consensus Group 1990-1991), the Keystone Center Dialogue for Transmission Line
Siting a national group developing EMF Policy 1991-1992), and the International
Electric Transmission Perception Project. Between 1977 and 1981, I served as a
member of the California Board of Registration for Professional Engineers Department
of Consumer Affairs). I am a full member of the Bioelectromagnetics Society. I am the
co-editor of the Biolnitiative Report, and a founding member of the Biolnitiative Working
Group, an international scientific and public health research collaboration. I was a
Lecturer in the Environmental Studies Program, University of California, Santa Barbara
and a founding member of that program, and developed and taught classes in
environmental impact assessment from 1972 1981.
4. My professional involvement in this area includes constraint analysis,
environmental planning, and impact assessment on EMF and radiofrequency radiation
siting issues for more than 30 years. My company has provided professional consulting
services to city and county planners, private developers, state and federal agencies and
schools with respect to measurement and assessment of EMF as a part of land
planning and environmental constraints analysis since 1972. I have been an expert
witness who testified on EMF computer modeling, impacts on people and property, EMF
policy, public perception, visual impairment and land use issues, and have qualified
both in state and in federal court proceedings as an expert witness in this area.
1
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PUBLIC COMMENT�T��"�|E�����A.10-04-018 EMF Safety Network
5. Sage Associates has prepared the report Assessment of Radiofrequency
Microwave Radiation Emissions from Smart Meters" http://sagereports.com/smart-
meter-rf/) to document radiofrequency radiation RF) levels associated with wireless
Smart Meters in various scenarios depicting common ways in which they are installed
and operated.
6. The report includes computer modeling of the range of possible smart meter RF
levels that are occurring in the typical installation and operation of a single Smart Meter,
and also multiple meters in California.
7. FCC compliance violations are likely to occur under normal conditions of
installation and operation of smart meters and collector meters in California, because
the public has access to Smart Meters installed on their homes.
8. In addition to exceeding FCC public safety limits under some conditions of
installation and operation, Smart Meters can produce excessively elevated RF
exposures, depending on where they are installed. RF levels are predicted to be
substantially elevated within a few feet to within a few tens of feet from the meter(s).
9. RF levels associated with Smart Meters under some conditions of installation and
operation will produce RF power density levels that exceed those reported in some
scientific studies to result in adverse health impacts, including headache, sleep
disruption, restlessness, tremor, cognitive impairment, tinnitus, increased cancer risk,
and cardiac problems at distances less than 500 meters from cell antennas, or at levels
over 0.1 microwatts per centimeter squared. 1.2.3.4.5.6
10. 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.
11. People who are afforded special protection under the federal Americans with
Disabilities Act are not sufficiently acknowledged nor protected. People who have
medical and/or metal implants or other conditions rendering them vulnerable to health
2
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PUBLIC COMMENT�T��"�|E�����A.10-04-018 EMF Safety Network
risks at lower levels than FCC RF limits may be particularly at risk.
12. 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.
13. 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 on a 24-hour basis.
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.
14. In summary, no positive assertion of safety can be made by the FCC, nor relied
upon by the CPUC, with respect to pulsed RF when exposures are chronic and occur in
the general population. 3.5.6 Indiscriminate exposure to environmentally ubiquitous
pulsed RF from the rollout of millions of new RF sources smart meters) will mean far
greater general population exposures, and potential health consequences.
Uncertainties about the existing RF environment how much RF exposure already
exists), what kind of interior reflective environments exist reflection factor), how interior
space is utilized near walls), and other characteristics of residents age, medical
condition, medical implants, relative health, reliance on critical care equipment that may
be subject to electronic interference, etc.) and unrestrained access to areas of property
where meter is located all argue for caution.
1. Khurana VG Hardell L Everaert J Bortkiewicz A Carlberg M Ahonen M, 2010.
Epidemiological Evidence for a Health Risk from Mobile Phone Base Stations. Int Journal of
Occupational Environmental Health 2010;16:263-267.
2. Kundi M Huffer HP Mobile phone base stations-Effects on wellbeing and health.
Pathophysiology 16 2009) 123-135.
3. Sage C. Carpenter DO. 2009. Public Health Implications of Wireless Technologies.
Pathophysiology 16 2009) 233-246.
4. Hardell L Sage C. Biological effect from electromagnetic field exposure and public exposure
standards. Biomedicine & Pharmacotherapy 2008;62:104-109. doi:10.1016/j.bipha.2007.12.004.
5. Biolnitiative Working Group, Cindy Sage and David O. Carpenter, Editors. Biolnitiative Report:
A Rationale for a Biologically-based Public Exposure Standard for Electromagnetic Fields ELF
and RF) at www.bioinitiative.org, August 31, 2007.
3
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PUBLIC COMMENT�T��"�|E�����A.10-04-018 EMF Safety Network
6. Carpenter DO Sage CL. 2008. Setting Prudent Public Health Policy for Electromagnetic Field
Exposures. Reviews on Environmental Health 23(2) 91-117.
Under penalty of perjury, I declare that the facts set forth above are true and
correct to the best of my knowledge.
Dated January 5, 2011, at Santa Barbara, California.
/s/
Cynthia Sage
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PUBLIC COMMENT�T��"�|E�����A.10-04-018 EMF Safety Network
VERIFICATION
I, Sandra Maurer, represent EMF Safety Network and am authorized to make this
verification on the organization's behalf. The statements in the foregoing document are
true to the best of my knowledge, except for those matters that are stated on
information and belief, and as to those matters I believe them to be true.
I declare under penalty of perjury that the foregoing is true and correct.
Dated January 5, 2011, at Sebastopol, California.
/s/
Sandra Maurer, Founder
EMF Safety Network
PO Box 1016
Sebastopol CA 95473
Tel. 707) 824-0824
sandi@a emfsafetynetwork.org
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PUBLIC COMMENT�T��"�|E�����A.10-04-018 EMF Safety Network
CERTIFICATE OF SERVICE
I certify that I have by electronic mail this day served a true copy of the original
attached Application of EMF Safety Network for Rehearing of Decision 10-12-001" on
all parties of record in A.10-04-018 or their attorneys of record. I will mail paper copies
of the pleading to Assigned Commissioner Michael Peevey and Administrative Law
Judge Timothy Sullivan.
Dated January 5, 2011, at Sebastopol, California.
/s/
Sandra Maurer
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SIGNED BOARD REPORT"�|E�4�MONTEREY COUNTY BOARD OF SUPERVISORS
MEETING: January 11, 2011 AGENDA NO.: 38
SUBJECT: Accept a written report from Dr. Hugh Stallworth, Director of Public Health/Health
Officer regarding Smart Meters Referral # 2010.20).
DEPARTMENT: Health Department Public Health
RECOMMENDATION:
It is recommended that the Board of Supervisors:
Accept a written report from Dr. Hugh Stallworth, Director of Public Health/Health Officer regarding
Smart Meters Referral # 2010.20).
SUMMARY/DISCUSSION:
On August 24, 2010 the Board of Supervisors submitted to the Health Department Referral #2010.20, to
consider a moratorium on installation of Smart Meters by Pacific Gas & Electric in Monterey County
pending resolution of consumer concerns.
Attached is a written report that was provided to the County Administrative Officer and the Health &
Human Services Committee regarding health concerns expressed by Monterey County residents,
centered around the issue of radio frequencies RF) produced by these devices is attached. Attachment
A)
OTHER AGENCY INVOLVEMENT:
County Counsel, Environmental Health
FINANCING:
There is no impact on the General Fund associated with this presentation.
Prepared by:
Approved by:
use McKee iiullick
Administrative Secretary Director of Health
/- 2-9- /0
Date
12-21-/a
Date
Attachment: Report on Smart Meters Referral # 2010.20)
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REVISED BOARD ORDER"�|E��38
Before the Board of Supervisors in and for the
County of Monterey, State of California
Accept a written report from Dr. Hugh
Stallworth, Director of Public Health/Health
Officer regarding Smart Meters Referral #
2010.20)
Upon motion of Supervisor Parker seconded by Supervisor Armenta, and carried by those
members present, effective January 11, 2011, the Board hereby;
Accept a written report from Dr. Hugh Stallworth, Director of Public Health/Health
Officer regarding Smart Meters Referral # 2010.20).
CONTINUED TO A FUTURE DATE this 11th day of January 2011, by the following
vote, to wit:
AYES: Supervisors Armenta, Calcagno, Parker, Potter
NOES: None
ABSENT: Supervisor Salinas
I, Gail T. Borkowski, Clerk of the Board of Supervisors of the County of Monterey, State of California,
hereby certify that the foregoing is a true copy of an original order of said Board of Supervisors duly made
and entered in the minutes thereof of Minute Book 75 for the meeting on January 11, 2011.
Dated: January 18, 2011 Gail T. Borkowski, Clerk of the Board of Supervisors
Revised: February 7, 2011 County of Monterey, State of California
By Deputy
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