Jeffry Fawcett, PhD talks about the multiple risks of wireless ‘smart’ meters at a recent community forum hosted by North Bay Patriots. Dr. Fawcett is an environmental economist, writer, and health educator. He produces the Your Own Health And Fitness radio show radio show with co-producer and host Layna Berman. He is the principal author of Too Much Medicine, Not Enough Health, written with Layna Berman.

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“EPRI’s comment letter mischaracterizes information presented in the Sage Report, and then attacks its own mischaracterizations.”

Sage Associates Response to a critique of The Sage Report on RF Exposures from Wireless ‘Smart’ Meters February 14, 2011
[This response is available in PDF download from the Sage Report site. We reproduce it in full here for our readers’ convenience. ]

SUMMARY
EPRI (The Electric Power Research Institute) conducts research on issues of interest to the electric power industry, and is largely funded by electric utilities in the United States. It has produced a comment dated February 2011 on the Sage Associates Smart Meter RF Assessment (January 1, 2011). [ Download PDF of EPRI document here. ]

We are gratified that this organization has detailed its opinions about the technical approach and conclusions of our Report. It allows for a fair and open discussion on whether our Report has properly addressed potential FCC violations for uncontrolled public access, conducted the correct technical analysis, and whether the conclusions of the Sage Report are reasonable. EPRI’s comment validates that the Sage Report has done so.

EPRI has presented no evidence of technical errors in the approach or calculations in the Sage Report, so the public and policy makers can rely on our conclusions and recommendations.

EPRI did not present calculations using the FCC OET Bulletin 65 equations that are fundamental to predicting RF levels. Thus, no apples-to-apples comparison can be made from their selective presentation of examples of RF levels. EPRI gave none of the basic information needed to check their figures. They provided no comprehensive assessment using the same FCC OET 65 equations, nor the range of possible duty cycles or reflection factors, nor specifying what power output, gain, effective radiated power (ERP) or other critical factors were used in their selected examples.

The FCC’s OET Bulletin 65 Equations provide the correct way to predict RF power density levels from smart meters, in advance of deployment.

Testing laboratories in the United States have used FCC OET Bulletin 65 equations to meet FCC compliance testing requirements.

The FCC has issued Grants of Authorization based on FCC OET 65 testing, including RF Exposure studies based on FCC OET 65 predictions to validate manufacturer requests for FCC compliance.

Such Grants of Authorization are “the piece of paper” that demonstrate the FCC has certified a particular smart meter to comply with FCC public safety limits, based on test results submitted by certified laboratories. Deviations in the installation or operation of smart meters may result in non-compliance with the limitations on the Grant of Authorization. Such Grants are relied upon by other governmental agencies, such as public utility commissions, who hold the FCC responsible for compliance determinations.

EPRI’s comment letter mischaracterizes information presented in the Sage Report, and then attacks its own mischaracterizations.

For Example

The Sage Report did properly apportion the power density contributions of each antenna to ERP calculations, as is documented on page 32-33 of the Report.

EPRI mischaracterizes the Sage Report by wrongly attributing that “duty cycle need not be taken into account, and that continuous exposure should be assumed.” This is incorrect (page 13, #1). The Sage Report provides comprehensive computer modeling results for duty cycles between 1% and 100%, at ten percent increments (see Tables A-1 through A16; see tables A17-A48). Time-averaging and reflections for 60% and 100% reflections are provided in the report, documented in the Methodology Section and both tables and text analysis are included throughout the Report.

Absent from EPRI’s comment is an acknowledgement of the FCC’s own requirement to use a 100% duty cycle where the public cannot be excluded. This is specifically discussed in the Sage Report on pages 22 -23 and 31-36.

“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 Bulletin OET 65, p, 10

EPRI’s comment (page 13, #2-4) is incorrect in that the Report did not take into account a reasonable approximation of distance from multiple meters. The contributions of multiple meters were derived by considering the distance and angle of each of the multiple meters from the reference point. Power density calculations in accord with FCC OET 65 were then used for multiple RF source predictions. Multiple meters were weighted according to their increasing distance from the point of occupied space in all calculations.

Having misrepresented key sections of the Sage Report, EPRI then tries to shift the discussion off-track and substitutes other methods of testing of smart meters that are based on either very low power density levels (limited number of measurements with no idea of duty cycle, reflections or other important factors) or nonsensical applications such as SAR, which is a method for testing cell phones and personal wireless devices, which smart meters are not.

EPRI comments at length on its views on reflection factors. The Sage Report includes two reflection factors specified by FCC OET 65 and two additional reflection factors that take into account newer, published scientific studies that show greatly increased RF power density can occur where there is highly reflective surface area. The Hondou studies (Hondou, 2002 and Hondou, 2006) support using higher reflection factors, as discussed in the Report. These studies find up to 1000 times or 2000 times the RF levels can occur in certain, highly reflective environments but would not be predicted using only the the more conservative FCC OET 65 equations.

The Sage Report nonetheless did not use reflection figures as high as measured in Hondou, 2002 or Hondou, 2006. The Sage Report uses only part of this predicted increase. We used 1000% (121 times rather than 1000 times) and 2000% (441 times rather than 2000 times) that of the Hondou studies.

EPRI is free to opine about what it considers reasonable, but provides no evidence that some interior environments cannot contain highly reflective environments that will increase interior RF levels. Further, the reader can read and reason. Some members of the public and decision-makers can decide which factors are reasonably applied, and draw conclusions accordingly. At least the Sage Report provides a clear and technically correct basis over the range of possible RF levels from smart meters.

It should be required of the utilities deploying the meters to do likewise (provide comprehensive, systematic RF power density predictions using all relevant factors, in run-out tables for power density versus distance, at various reflection factors and all duty cycles, including 100% in accord with FCC OET 65).

Neither the utilities involved, nor the CPUC, Division of Ratepayer Advocates or EPRI have provided their own studies on RF power density and compliance findings using FCC OET Bulletin 65 and specified equations, and adhering to the same requirements contained in that protocol. If they had done so, the calculations would be very similar or exactly that published in the Sage Report. None of these groups has found technical flaws in the Sage Report – which properly applied the FCC OET Bulletin 65 formulas. The Sage Report found many instances where wireless meters will violate FCC public safety limits in the manner they are installed and operated, and no evidence has been offered that demonstrates its conclusions to be in error.

For every type of smart meter installed with a utility’s service area, this includes but is not limited to the manufacturer, the FCC Id number, the make and model information, a copy of the RF Exposure Report from the testing lab and Grant of Authorization certified by the FCC. It includes the operating frequency for each antenna (or range of frequencies), antenna pattern characteristics for each antenna, the maximum power output, maximum antenna gain, maximum duty cycle mechanically possible considering all signals that may be transmitted through it (this includes the meter itself, piggybacking of signals from nearby meters, power transmitters installed on appliances), which antennas can transmit simultaneously, the dimensions of each antenna within the meter and the actual ‘as-built’ separation of each antenna, and other key factors critical to independent evaluation of RF emissions and exposure levels.

EPRI points out that in 2005, the IEEE (the Institute for Electrical and Electronics Engineers, Inc) adopted new measures to relax existing public safety limits, including those for RF exposures to the eyes and testes. The IEEE also adopted a new 10-gram volume of tissue, replacing a one-gram volume of tissue to allow dissipation of thermal energy (SAR). IEEE’s recommendation was to increase the tissue volume to 10 grams (a five-fold increase in allowable energy). It is notable that the FCC did not agree, and did not adopt these IEEE recommendations.

The public is not well served, nor do policy-makers have sufficient information on impacts and adverse consequences of an enormously costly new wireless technology without full disclosure of RF emissions and resulting exposures to families in their own homes, schools, public buildings, businesses, hospitals, libraries, shopping, entertainment and transportation.

The issue of health effects as presented by EPRI simply reflects their continuing view that there are divergent views. We agree with this, but underscore that industry and its close representatives and partners generally say they will only consider ‘clear and consistent evidence to document a causal role of RF exposures in connection with human cancer or other disease endpoints’. This is to be expected from industry.

But, policy makers must not just look after the interests of industry, but take good public health planning principles into account. When there is reasonable evidence for risks from new technologies, it is not in the public interest, nor the economic interests of the State to wait endlessly for all parties to agree there is “causal evidence or proof” position in order to take reasonable actions to protect public health. This is particularly true when considering the wisdom of widespread, involuntary public exposures to new technologies for which there is substantial evidence (but not yet proof) of possible health harm to millions of people. It could cost billions to fix in later years, result in economic harm to the State and its residents, and cause even deeper dissatisfaction with the State’s regulatory agency performance.

No positive assertion of safety can be made by the parties involved in this issue without better, independent information. Currently, the data made available by the utilities that are installing smart meters is non-existent, piecemeal and without sufficient basis to verify. In addition, there are different types of meters being deployed, so a full accounting of each one should be public information.
End of Sage Associates’ Response

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Please remember, your bite-size contributions on our Donate Page are what help keep us going. You can also send a check made out to EON to EON, POB 1047, Bolinas, CA

B. Blake Levitt is an award-winning science journalist who has researched the biological effects of nonionizing radiation since the late 1970’s. She is the author of “Electromagnetic Fields, A Consumer’s Guide to the Issues and How to Protect Ourselves,” and is on the executive board of The Berkshire-Litchfield Environmental Council. For an in-depth interview with her and Duncan Campbell, Esq by Camila Rees go to ElectroMagneticHealth.com

The Bulletin (CTBulletin.com)
Opinion > Op-ed
Chris Murphy: Smart Guy, Big Blindspots
Thursday, March 3, 2011
By B. Blake Levitt

Area Democrats were recently asked to endorse Chris Murphy for his upcoming bid for the U.S. Senate. Full disclosure—I am a lifelong Democrat, an ardent environmentalist, and vice chairman of the Warren Democratic Town Committee.

My most delicious guilty political pleasure, however, is voting repeatedly for Republicans Andrew Roraback for the Connecticut Senate and Jack Travers for First Selectman in Warren—both terrific, civic-minded gentleman, party affiliation be damned. But as a fellow Dem, I’ve got problems with Chris Murphy—also an ardent environmentalist—that surprise even me.

As a former member of the U.S. House Committee on Energy and Commerce, in my opinion, Chris Murphy focused too hard on pushing big-picture environmental solutions (to combat climate change and support alternative energy) to the detriment of significant issues on the ground. It’s as if he presumes local objections are ipso facto NIMBY (not-in-my-backyard) concerns, or just too provincial for serious attention. He has also come to embrace technology as a primary problem solver without understanding that a too-rapid embrace of some technologies can create unique environmental problems all of their own. And with only a handful of exceptions, he has also been unresponsive to requests for help regarding cell tower issues at the federal level when important actions there could alleviate local problems all across the country. His staff has been chronic no-shows at important briefings on radiofrequency radiation (RF) issues, despite repeated invitations. That office just seems to “know what it knows” about the environment and that’s the end of it.

My particular issue with Congressman Murphy concerns his support for SmartGrid technologies, and I will not endorse or support him until he backs away from this ill-conceived massive overhaul of the nation’s utility grid. While no sane person could argue that our aging utility infrastructure does not need upgrading, or that government has no role to play, Smart Grids as currently designed aren’t the way. SmartGrid/SmartMeter technologies are poised to force a new layer of RF radiation into our lives, whether we want it or not. This, at a time when there are increasing concerns in medical research circles about the safety of such low-level, chronic RF exposures, made ubiquitous by all our beloved wireless gizmos—from cell phones to iPads to Wi-Fi—and all their accompanying transmitting infrastructure. No agency regulates for aggregate exposures from all these devices. Exposure guidelines at the Federal Communications Commission (FCC) are taken one device at a time. But at least with cell phones, exposures are voluntary. Not so with SmartGrids/SmartMeters.

SmartGrids—funded to the tune of 11 billion taxpayer dollars today, mainly through Congressman Murphy’s former committee in league with the Department of Energy, will eventually turn all of our appliances into RF transceivers just like cell phones, capable of being controlled remotely by us and the utility companies. That’s every washer, dryer, computer, stove, oven, furnace, air conditioner, and on and on—all turned into cell-phone like devices. New appliances are already being equipped with internal antennas. All of these indoor transmitters will communicate with SmartMeters attached to the outside of homes and businesses, which will, in turn, transmit utility usage information several times a day, and sometimes several times a minute, to a new centralized hub (like a cell tower) coming to a location near you soon. Peak power busts of RF when a device first transmits have been measured in excess of federal guidelines. These are unsafe, involuntary exposures, especially to pregnant women and children.

Northeast Utilities in Connecticut is currently requesting permission from the Department of Public Utility Control (DPUC), which will rule in April, to install SmartMeters on the homes of 1.2 million customers. This is after a 2009 pilot program of 10,000 residential, small commercial, and industrial customers found no beneficial impact on total energy usage. Connecticut Attorney General George Jepsen and the Office of Consumer Counsel have asked the DPUC to slow down, and for good reason. In a brief filed Feb. 8, Mr. Jepsen estimated that this “upgrade” will cost ratepayers over $500 million for the meters alone. The energy savings cannot justify the costs, he said. There are privacy concerns, too. Indeed.

There is backlash in other states. Thousands of citizens and scores of legislators throughout California and Maine are calling for moratoriums until more is known. Mothers and grandmothers have been arrested for blocking utility trucks from entering their neighborhoods. Five California communities have declared SmartMeters “illegal,” including San Francisco. Lawsuits are pending.

People are reporting intense headaches, “brainfog,” insomnia, and chronic flu-like symptoms—classic low-level RF complaints—within days of smart meters being installed on homes. Over 2,500 people have phoned California’s Pacific Gas & Electric with health problems. Numerous fires have started from improperly installed meters.

Billing errors have become rampant with SmartMeters, sometimes tripling within one month of installation. Radiofequency interference is affecting other appliances, too, making them run erratically and burning out circuit boards. General radio reception is adversely affected in some homes. There are concerns regarding RF interference with insulin pumps, some pacemakers, electric wheelchairs, in-home hospital equipment and deep brain stimulators used in Parkinson’s patients. SmartMeters are also easily hacked into. Security firms have demonstrated how easy it is to penetrate the entire grid through a single meter, thereby endangering national security. Individual security is also at risk; personal information about real-time energy use can signal when people are not home. Then there are privacy concerns … what’s to stop someone from selling information about you, once they have access to how and when you use your appliances?

And there are social issues: SmartMeters allow two-way communication between the utility company and all of your appliances. But do we really want them to control our furnaces and air conditioners? Or risk appliances accidentally turning on or off via errant cell phone signals from a passing motorist when we aren’t at home? (The systems are very “buggy.”) Or allowing utilities to set tiered pricing for higher rates during the day—a “green” business model intended to get people to run their appliances at off-peak hours. This penalizes the elderly, stay-at-home children/families, freelancers, home-based businesses and the unemployed.

The big question, though, is whether this multibillion-dollar debacle will actually save energy. Nowhere has anyone factored in the reality that all of these new antennas will create something called vampire energy (think remote-controlled appliances like TV’s that are never really “off” unless fully unplugged or they wouldn’t be able to turn back “on” when asked to do so.) Or the fact that the constant stepping up and down of various voltages between the higher frequency RF meters and the lower frequency utility lines use far more energy than just leaving them alone. Or the gas required for all those vans to convert literally billions of meters all over the country. Or the energy required to dispose of the old meters. Or the simple fact that some people can’t do their laundry at midnight?

SmartGrid technology is vastly more complex than our ability to control it. Yet, in the name of saving energy and creating green jobs, Mr. Murphy and many environmental organizations like the Sierra Club, are prime supporters. There’s a serious disconnect here.

To garner my support, Mr. Murphy needs to do much better homework. Federal stimulus dollars should not be used this way. For $11 billion, we could have brought fiberoptic cable to every home the way Japan has done. Fiberoptic can be used for high-speed Internet, TV, voice communications, and oh yeah, real-time utility billing if anyone keeps thinking that’s a bright idea. Several U.S. municipalities have invested in their own private to-the-home fiberoptic systems and now offer significant tech/entertainment savings to residents. It’s the ultimate competition with the cable companies. There is also no RF with fiberoptic and virtually no downtime in catastrophic emergencies. That’s the infrastructure taxpayers should be supporting.

What’s more, much of the taxpayer money for SmratGrids has gone to corporate behemoths like Seimens and GE—the largest manufacturer of SmartMeters in the world. And then there’s the irony that SmartMeters don’t “run backwards” with many green technologies like solar panels. So much for selling back to the grid and recouping investments. Even Forbes Magazine is now saying that the SmartGrid isn’t such a smart investment afterall.

Other countries are far ahead of us in calling for precautionary measures. New Zealand counties have outlawed SmartMeters because of fires. The European Union recommends that people keep wireless use to a minimum. In France, the national library system has outlawed Wi-Fi computers throughout that nation’s libraries because librarians became ill. The German government recommends that citizens maintain their landline phones and that people of childbearing age not use wireless computers on their laps due to fertility comcerns. There is massive resistance over SmartGrid deployment throughout Europe.

Intelligent environmentalists like Chris Murphy need to go back to the drawing board. SmartGrids are just plain dangerous and dumb. And industrial-scale wind turbines do not belong just anywhere that the nascent wind industry wants to plunk them. Jobs and renewable energy are, of course, critical macro-issues, but our health, security, privacy, peace of mind, and local stewardship responsibilities are significant parts of the equation, too.