Santa Cruz Landmark 'Smart Meter' Ordinance & Health Impacts Report

‘Smart’ Meters Take the Lead in Whole-Body RF Exposure

Comparison of Radio-Frequency Levels to the Whole Body from Various Sources in IJ W/cm2 over time (corrected by Daniel Hirsch, Committee to Bridge the Gap, & UCSC Nuclear Policy lecturer, for assumed duty cycle and whole body exposure extrapolated from EPRI/CCST SmartMeter estimated levels at 3 feet).

Rising to the Occasion – Law Makers Follow the Facts
As the California Public Utilities Commission (CPUC) moves toward a decision on its ‘smart’ meter opt-out policy, Santa Cruz County officials have taken the lead in producing a health report and crafting a responsible response to the industry attempt to force wireless ‘smart’ meters on the entire population without scientific testing or informed democratic consent.  [ Download the PDF of here. ] While this revised proposed decision is a giant step forward in that it would allow the analog meters that are relatively safe and do not emit RF, it does not go far enough.

Nina Beety

A report by Santa Cruz County Health Officer Dr. Poki Stewart Namkung, casting serious doubt on Smart Meter safety and the adequacy of FCC guidelines to protect the public, was unanimously accepted by the Santa Cruz County Board of Supervisors. The board also approved renewing their Smart Meter moratorium ordinance, and will be adding their names to a petition to the California Public Utilities Commission circulating among county and city officials.

From the health department report “Health Risks Associated with Smart Meters”:

“Evidence is accumulating on the results of exposure to RF at non-thermal levels. including increased permeability of the blood-brain barrier in the head, harmful effects on sperm, double strand breaks in DNA which could lead to cancer genesis…”

“When it comes to nonthermal effects of RF, FCC guidelines are irrelevant and cannot be used for any claims of SmartMeter safety unless heat damage is involved.”

“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…”

The report includes ways to reduce exposure to EMF from cell phones, wireless internet, and other wireless and EMF devices.

The full report, as well as the letter from Santa Cruz County CAO Susan Mauriello recommending today’s actions, is here.

Santa Cruz County Administrative Office: 831-454-2100
Santa Cruz County website.

Michigan Launches SM Probe
Elsewhere in the news, the Michigan Public Service Commission (MPSC) has launched an investigation into the deployment of smart meters by regulated electric utilities in Michigan.

Noting that electric customers and several municipalities have expressed concern about the deployment of smart meters by electric utilities operating in Michigan, the MPSC today opened a docket for the purpose of addressing these concerns to the degree possible, in light of the limits of the Commission’s statutory authority and expertise.

Today’s order directs all regulated electric utilities to submit information to the Commission in Case No. U-17000 by March 16 on the following topics:
* The electric utility’s existing plans for the deployment of smart meters in its service territory;
* The estimated cost of deploying smart meters throughout its service territory and any sources of funding;
* An estimate of the savings to be achieved by the deployment of smart meters;
* An explanation of any other non-monetary benefits that might be realized from the deployment of smart meters;
* Any scientific informa­tion known to the electric utility that bears on the safety of the smart meters to be deployed by that utility;
* An explanation of the type of information that will be gathered by the electric utility through the use of smart meters;
* An explanation of the steps that the electric utility intends to take to safeguard the privacy of the customer information so gathered;
* Whether the electric utility intends to allow customers to opt out of having a smart meter; and
* How the electric utility intends to recover the cost of an opt-out program, if one will exist.

Back to Santa Cruz
We post excerpts of the Santa Cruz documents below. You can download a PDF of the document package here.

County of Santa Cruz
701 OCEAN STREET, SUITE 520, SANTA CRUZ, CA 95060-4073
(831) 454-2100 FAX: (831) 454-3420 TOO: (831) 454-2123
January 18, 2012
AGENDA: January 24,2012
Board of Supervisors
County of Santa Cruz
701 Ocean Street
Santa Cruz, California 95060

SmartMeter Moratorium

Dear Members of the Board:
On December 13,2011, your Board directed this office to return today with a report on issues associated with the current SmartMeter moratorium ordinance, and information on the possible extension of the moratorium for an additional year. Your Board also directed the Public Health Offcer to return with an analysis of the research on the health effects of SmartMeters, and directed County Counsel to return with a report regarding the legality of a public utility refusing service to customers who are willing to pay for service and are willing to have an analog meter.

As your Board is aware, the California Public Utility Commission is considering PG&E’s
application for modification to PG&E’s SmartMeter proposal to include an option for residential customers who do not wish to have a wireless SmartMeter. The item was scheduled on the January 12, 2012 agenda, but the commission anticipates that a vote on the proposal will not happen prior to February 1,2012. Moratorium Ordinance
Your Board has heard significant amounts of testimony regarding SmartMeters and concerns about their possible impact on health, questions about their accuracy, their inability to recover real-time data, privacy concerns, and the lack of safety standards for chronic long-term exposure to electromagnetic frequency radiation. In addition, PG&E has not presented studies to support their primary justification that the SmartMeter program will encourage customers to more effectively manage their utilization of electricity.

Given the broad concern about SmartMeter technology and your Board’s desire to go on record, this offce and County Counsel believe that notwithstanding the enforcement challenges, that it is in the best interest of public health, safety, and welfare for your Board to adopt the attached ordinance (Attachment A) implementing a temporary moratorium on the installation of SmartMeters in or on any home, apartment, condominium or business within the unincorporated area of the County. The purpose of the moratorium is to allow additional time to educate the CPUC about these concerns and allow time for adequate study of the impacts resulting from the SmartMeter technology.

Ordinance Imposing Temporary Moratorium on Installation of SmartMeters
Agenda: January 24, 200 i 2

PG&E, asserting that local governments do not have jurisdiction on the installation of the meters, has ignored the previous Santa Cruz County ordinance as well as similar ordinances adopted in other jurisdictions. PG&E believes that only the California Public Utilities Commission (CPUC) has the authority to stop installation of the meters. Elected representatives, including the Board of Supervisors of Marin County, have acknowledged the limits of their ordinances to actually stop the installation of the meters. However, jurisdictions have adopted their ordinances with statements that such ordinances play an important role by informing the CPUC of significant community concerns.

Health Offcer Report
The Public Health Offcer’s report is provided as Attachment B. The report discusses the health risks associated with SmartMeters, the scientific reports and actions the public might take to mitigate potential harm.

PG&E Shutoff Update
At the December 13, 201 i, meeting, your Board questioned the PG&E representative about the utility company’s decision to shut off power to the homes of residents who removed their SmartMeters. Subsequent to that meeting, PG&E restored power to those residences with the intent of charging them based on past electrical bills.

At your January 10, 2012 meeting, your Board was presented with a petition to the California Public Utilities Commission regarding PG&E SmartMeter Opt-out Application, The petition provides the opportunity for local elected offcials to urge the Commission
to continue Petition A.II-03-0 14 for further public hearings. The petition is provided as
Attachment C. It is recommended that your Board direct the Chair to sign the petition on behalf of the Board and submit it to the PUC.
(1) Direct the Chair to send a letter to the PUC calling for independent testing and
monitoring of SmartMeters in place to determine duty cycles and frequency, especially
in the following circumstances:

. Where both gas and electric meters are located closely together
. Where there is a bank of SmartMeters such as on a multi-family residential
building or apartment building
. Where there is a collector meter on a home that serves the home, plus as many
as 5000 other residential units in the area
. Where a SmartMeter on a home acts as a relay for other local neighborhood

Ordinance Imposing Temporary Moratorium on Installation of Smart Meters

(2) Direct the Chair to send a letter to the PUC and PG&E allowing any Santa Cruz
County resident to request removal of a previously installed SmartMeter and the
replacement with an analog meter
(3) Accept and file the report from the Public Health Officer
(4) Direct the Chair to sign the petition to the California Public Utilities Commission on
behalf of the Board urging the Commission to delay consideration of a preliminary
decision on PG&E’s SmartMeter application until further public hearing and input are
completed, and
(5) Adopt the attached ordinance imposing a temporary moratorium on the installation of
SmartMeters within the unincorporated area of Santa Cruz Comity and direct the Clerk
of the Board to place the ordinance on the February 7, 2012 agenda for final consideration.

A. Proposed Ordinance
B. Report from Public Health Offcer
C. Petition to CPUC
cc: PG&E
California Public Utilities Commission


Attachment A

The Board of Supervisors of the County of Santa Cruz find as follows:

WHEREAS, the County of Santa Cruz (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 Santa Cruz has a franchise agreement with PG&E that has been in effect since 1955; and

WHEREAS, in addition, the County retains authority under Article XII, Section 8 of the Constitution to grant franchises for public utilties, and pursuant to California Public Utilties 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 utilty, 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 installng SmartMeters in Central and Northern California and is installing these meters within the County of Santa Cruz; 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 currently has pending 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 Santa Cruz, 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 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, significant health questions have been raised concerning the increased electromagnetic frequency radiation (EMF) emitted by the wireless technology in SmartMeters, which wil be in every house, apartment and business, thereby adding additional human-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 wil 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 enhanced customer education is a viable non-technological alternative to encourage electricity use time shifting. 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, this Board of Supervisors sent a letter to the CPUC on September 15, 2010 expressing concern about reports that SmartMeter technology was interfering with the proper functioning of common household devices and requesting a response from the CPUC; and

WHEREAS, there has been no response by the CPUC to the letter sent by the Board of Supervisors; 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 Santa Cruz. 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 Santa Cruz 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 possibilty 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, 2012, 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 Santa Cruz as follows:
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 Santa Cruz, 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 Santa Cruz.

Violations of the Moratorium may be charged as infractions or misdemeanors as set forth in Chapter 1.12 of the Santa Cruz County Code. In addition, violations may be deemed public nuisances, with enforcement by injunction or any other remedy authorized by law.

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 Santa Cruz County by preserving and improving the aesthetic and economic conditions of the County.

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 are
severable from the remainder and the remainder is given full force and effect.

This interim ordinance is not subject to the California Environmental Quality Act (CEQA) pursuant to Section 1 5060( 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….

Attachment B
[ For sources cited, please see PDF version. ]

Date: January 13, 2012
To: Santa Cruz County Board of Supervisors
From: Poki Stewart Namkung, M.D., M.P.H., Health Officer
Subject: Health Risks Associated With SmartMeters

On December 13, 2011, Santa Cruz County Board of Supervisors directed the Public
Health Officer to return on January 24, 2012, with an analysis of the research on the health
effects of SmartMeters.

In order to analyze the potential health risks associated with SmartMeters, the following
questions should be asked:

1) What is the SmartMeter system and what is the potential radiation exposure from the system?
2) What scientific evidence exists about the potential health risks associated with SmartMeters?
3) Are there actions that the public might take to mitigate any potential harm from SmartMeters?

SmartMeters are a new type of electrical meter that will measure consumer energy usage
and send the information back to the utility by a wireless signal in the form of pulsed
frequencies within the 800 MHz to 2400MHz range, contained in the microwave portion of
the electromagnetic spectrum. SmartMeters are considered part of ‘smart grid’ technology
that includes: a) a mesh network or series of pole-mounted wireless antennas at the
neighborhood level to collect and transmit wireless information from all SmartMeters in that area back to the utility; b) collector meters, which are a special type of SmartMeter that
collects the radiofrequency or microwave radiation signals from many surrounding buildings (500-5000 homes or buildings) and sends the information back to the utility; and
c) proposed for the future, a power transmitter to measure the energy use of individual
appliances (e.g. washing machines, clothes dryers, dishwasher, etc) and send information
via wireless radio frequency signal back to the SmartMeter. The primary rationale for
SmartMeters and grid networks is to more accurately monitor and direct energy usage.
The public health issue of concern in regard to SmartMeters is the involuntary exposure of
individuals and households to electromagnetic field (EMF) radiation. EMFs are everywhere, coming from both natural and man-made sources.

The three broad classes of EMF are:
· extremely low frequency, ELF (from the sun or powerlines)
· radio frequency, RF (from communication devices, wireless devices, and SmartMeters)
· extremely high frequency, known as ionizing radiation (x-rays and gamma rays)

Much of this exposure is beyond our control and is a matter of personal choice; however,
public exposure to RF fields is growing exponentially due to the proliferation of cell phones, and wireless fidelity (Wi-Fi) technology. To understand the relationship between EMF from SmartMeters and other sources, it is helpful to view the electromagnetic spectrum:

Fig. 1: The Electro-Magnetic Spectrum, showing the relations between ELF and RF fields, waveleigth aid frequency, and the ionizing and non-ionizing portions of the spectrum.

The Federal Communications Commission (FCC) has adopted limits for Maximum
Permissable Exposure (MPE) that are based on exposure guidelines published by the
National Council on Radiation Protection and Measurements (NCRP). The limits vary with
the frequency of the electromagnetic radiation and are expressed in units of microwatts per
centimeter squared. A SmartMeter contains two antennas whose combined time-
averaged public safety limit of exposure is 655¡.W/cm2 (Sage, 2011). According to the
California Council on Science and Technology (CCST) Report (2011), within distances of
three to ten feet, SmartMeters would not exceed this limit.

However, CCST did not account for the frequency of transmissions, reflection factors, banks of SmartMeters firing simultaneously, and distances closer than three feet. There are numerous situations in which the distance between the SmartMeters and humans is less than three feet on an ongoing basis, e.g. a SmartMeter mounted on the external wall to a bedroom with the bed placed adjacent to that mounting next to the internal walL. That distance is estimated to be one foot. The CCST Report also states that SmartMeters will generally transmit data once every four hours, and once the grid is fully functional, may transmit “more frequently.” It has been aptly demonstrated by computer modeling and real measurement of existing meters that SmartMeters emit frequencies almost continuously, day and night, seven days a week. Furthermore, it is not possible to program them to not operate at 100% of a duty cycle (continuously) and therefore it should not be possible to state that SmartMeters do not exceed the time-averaged exposure limit. Additionally, exposure is additive and consumers may have already increased their exposures to radiofrequency radiation in the home through the voluntary use of wireless devices such as cell and cordless phones, personal digital assistants (PDAs), routers for internet access, home security systems, wireless baby surveillance (baby monitors) and other emerging devices. It would be impossible to know how close a consumer might be to their limit, making safety a uncertainty with the installation of a mandatory SmartMeter.

This report will focus on the documented health risks of EMF in general, the relevance of
that data to SmartMeters exposure, the established guidelines for RF safety to the public
at large, and then provide recommendations to ameliorate the risk to the public’s health.

Evidence-based Health Risks of EMFs
There is no scientific literature on the health risks of SmartMeters in particular as they are
a new technology. However, there is a large body of research on the health risks of EMFs.
Much of the data is concentrated on cell phone usage and as SmartMeters occupy the
same energy spectrum as cell phones and depending on conditions, can exceed the whole
body radiation exposure of cell phones phones (see Attachment B1, Figure 4). In terms of
health risks, the causal factor under study is RF radiation whether it be from cell phones,
Wi-Fi routers, cordless phones, or SmartMeters. Therefore all available, peer-reviewed,
scientific research data can be extrapolated to apply to SmartMeters, taking into
consideration the magnitude and the intensity of the exposure.

Since the mid-1990’s the use of cellular and wireless devices has increased exponentially
exposing the public to massively increased levels of RF. There is however, debate
regarding the health risks posed to the public given these increased levels of radiation. It
must be noted that there is little basic science funding for this type of research and it is
largely funded by industry. An intriguing divide, noted by Genuis, 2011 is that most
research carried out by independent non-government or non-industry affiliated researchers suggests potentially serious effects from many non-ionizing radiation exposures; most research carried out by independent non-government or non-industry affiliated researchers suggests potentially serious effects from many non-ionizing radiation exposures research funded by industry and some governments seems to cast doubt on the potential for harm.

Elements of the controversy stem from inability to replicate findings consistently in
laboratory animal studies. However, analysis of many of the conflicting studies is not valid
as the methodology used is not comparable. Despite this controversy, evidence is
accumulating on the results of exposure to RF at non-thermal levels including increased
permeability of the blood-brain barrier in the head (Eberhardt, 2008), harmful effects on
sperm, double strand breaks in DNA which could lead to cancer genesis (Phillips, 2011),
stress gene activation indicating an exposure to a toxin (Blank, 2011), and alterations in
brain glucose metabolism (Volkow, 2011).

In terms of meta-analyzed epidemiological studies, all case-control epidemiological
studies covering ;:10 years of cell phone use have reported an increased risk of brain
tumors from the use of mobile phones (Hallberg, 2011). Other studies have pointed to an
increasing risk of acoustic neuroma, salivary gland tumors, and eye cancer after several
years of cell phone use and the tumors occur predominantly on the same side of the head
as the phone is used. The analysis of brain cancer statistics since the mid 20th century in
several countries reveals that brain tumor formation has a long latency time, an average of
over 30 years to develop from initial damage.(Hallberg, 2011). Therefore using studies
such as the Interphone Study which looked as shorter latency periods for the development
of specific brain cancers will result in inconclusive data.

Another potential health risk related to EMF exposure, whose legitimacy as a phenomen
remains contentious, is electromagnetic hypersensitivity (EHS). In the 1950’s, various
centers in Eastern Europe began to describe and treat thousands of workers, generally
employed in jobs involving microwave transmission. The afflicted individuals often
presented with symptoms such as headaches, weakness, sleep disturbance, emotional
instability, dizziness, memory impairment, fatigue, and heart palpitations. Clinical research
to verify the physiological nature of this condition did not begin in earnest until the 1990’s
and found that the EMF involved was usually within the non-ionizing range of the
electromagnetic spectrum. In the early 2000’s, estimates of the occurrence of EHS began
to swell with studies estimating the prevalence of this condition to be about 1.5% of the
population of Sweden (Hilleert et ai’, 2002), 3.2% in California (Levallios et ai’, 2002), and
8% in Germany (infas Institut fur angewandte Sozialwissenschaft GmbH, 2003).
In 2004, WHO declared EHS “a phenomenon where individuals experience adverse health
effect while using or being in the vicinity of devices emanating electric, magnetic, or
electromagnetic fields (EMFs)… Whatever its cause, EHS is a real and sometimes
debilitating problem for the affected persons (Mild et ai’, 2004).”

Currently, research has demonstrated objective evidence to support the EHS diagnosis,
defining pathophysiological mechanisms including immune dysregulation in vitro, with
increased production of selected cytokines and disruption and dysregulation of
catecholamine physiology (Genuis, 2011).

Until recently, the diagnosis of EHS has not received much support from the medical
community due to lack of objective evidence. In an effort to determine the legitimacy of
EHS as a neurological disorder, however, a collection of scientists and physicians recently
conducted a double-blinded research study that concluded that “EMF hypersensitivity can
occur as a bona fide environmentally-inducible neurological syndrome (McCarty et ai’,
2011 ).

Safety Guidelines
The guidelines currently used by the FCC were adopted in 1996, are thermally based, and
are believed to protect against injury that may be caused by acute exposures that result in
tissue heating or electric shock. FCC guidelines have a much lower certainty of safety than
standards. Meeting the current FCC guidelines only assures that one should not have
heat damage from SmartMeter exposure. It says nothing about safety from the risk of
many chronic diseases that the public is most concerned about such as cancer,
miscarriage, birth defects, semen quality, autoimmune diseases, etc. Therefore, when it
comes to nonthermal effects of RF, FCC guidelines are irrelevant and cannot be used for
any claims of SmartMeter safety unless heat damage is involved (Li, 2011).
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. Many other countries (9) have
significantly lower RF/MW exposure standards ranging from 0.001 to 50 ~W/cm2 as
compared with the US guideline of 200-1 000 ~W/cm2. Note that these recommended
levels are considerably lower that the approximately 600 ~W/cm2. (time-averaged) allowed
for the RFR from SmartMeters operating in the low 900 MHz band mandated by the FCC
based on only thermal consideration.

In summary, there is no scientific data to determine if there is a safe RF exposure level
regarding its non-thermal effects. The question for governmental agencies is that given
the uncertainty of safety, the evidence of existing and potential harm, should we err on the
side of safety and take the precautionary avoidance measures? The two unique features
of SmartMeter exposure are: 1) universal exposure thus far because of mandatory
installation ensuring that virtually every household is exposed; 2) involuntary exposure
whether one has a SmartMeter on their home or not due to the already ubiquitous
saturation of installation in Santa Cruz County. Governmental agencies for protecting
public health and safety should be much more vigilant towards involuntary environmental
exposures because governmental agencies are the only defense against such involuntary
exposure. Examples of actions that the public might take to limit exposure to
electromagnetic radiation can be found in Attachment B2.

[ For references, please see PDF version. ]

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