January 29, 2011
Yasuko KatoJournalist
VOC-EMF Measures ResearchAssociation, Director
471, Bankei, Chuou-ku,Sapporo, Hokkaido,064-0945 JAPAN
Comment on CCST Smart Meter report
I am a journalist and a director of a self-help group for Multiple
Chemical Sensitivity (MCS) and Electromagnetic Hyper Sensitivity(EHS) in Japan. I am also a patient of MCS and EHS. So, I havebeen working to improve the environment for sensitivity people andvulnerable children.
The smart grid program is planning all over the world including Japan.
In our country, Smart Meters have installed in some area, and otherutilities are planning to install it as demonstratively experiment. So, I
have interested in Smart Meter issues in California and CCST report.
Why did not show the major factors?
CCST expressed the RF level was 40μW/cm2 at 3 feet from Smart
Meter. But, CCST did not show the important factors related to thiscalculation, such as a number of meters, an assumed environmental,
and reflection of building materials.
FCC limit never provide safety
FCC limits that based on thermal effects never provide safety togeneral people. Many studies have been described the adverse
health effect occurred by non-thermal effects under the limit ofInternational Commission of Non-Ionizing Radiation Protection(ICNIRP) that is same to FCC. The Bioinitiative Report mentioned“the body of evidence at hand suggests that bioeffects and healthimpacts can and do occur at exquisitely low exposure levels: levels
that can be thousands of times below public safety limits“ andrecommended the value of 0.1 μW/cm2 for RF. This value is ten

thousand times below FCC limits.
Why did not CCST describe about EHS ?
There is an important EHS article by P. Levallois et al. (2002). They
estimated the prevalence of self-reported sensitivity to EMF was3.2%, with 24.4% of those surveyed reporting sensitivity to chemicals,in California. It was necessary to have forecast the adverse healtheffect at the early stage of the smart grid program. In actually, many
people have been already claimed many symptoms by Radio
Frequency (RF) emission from PG&E Smart Meters. CCST have toseriously consider these claims.
The rights of person with EHS
I carried out a questionnaire survey in 2009 about health problem,economical, and social issues related to EHS in Japan. The valid
responses were only 75, however the total cost to avoid EMF, suchas moving to low EMF area, RF shielding reconstruction andreplacing to low emission household appliances, reached to about
168 million yen (about1.8 million US dollars). Fifty-three percent hada job before the EHS onset, but 65% of them lost their work or
experienced a decrease in income. Major symptoms were“fatigue/tiredness”(85%), and “headache”, “difficulty of concentrating,remembering and thinking” (81%, respectively) . Sixty five percent
indicated they experienced symptoms attributable to radiation fromother passengers’ mobile phones abroad public transportation,and12.0% said they could not use any public transportation due totheir serious symptoms. The survey indicated EHS people are
significantly limited their daily life due to EMF exposure.
EHS and MCS are publicly recognized as disabilities in U.S.A. underthe ADA. Federal Register (Sept. 3, 2002) mentioned “ The(Architectural and Transportation Barriers Compliance) board
recognizes that multiple chemical sensitivities and electromagnetic
sensitivities may be considered disabilities under the ADA if they areso severely impair the neurological, respiratory or other functions ofan individual that it substantially limits one or more the individual’smajor life activities.”
In 2005, National Institute of Building Science (NIBS) published thereport “Indoor Environmental Quality (IEQ) ” in according with therequest from the Architectural and Transportation Barriers

Compliance Board.
IEQ report mentioned ;“For people who are electromagnetically sensitive, the presence ofcell phones and towers, portable telephones, computers, fluorescentlighting, unshielded transformers and wiring, battery re-chargers,
wireless devices, security and scanning equipment, microwave
ovens, electric ranges and numerous other electrical appliances canmake a buildings inaccessible.”Then, they established the recommendations to increase the accessfor sensitivity people. It includes;
・Cell Phones Turned off
・ Ability to turn off or unplug computers and other electricalequipment by occupant or staff
・ Ability to turn off fluorescent lighting by occupant or staff“ The focus of the project was on commercial and public buildings,
but many of the issues addressed and recommendations offered inresidential settings”.
However, the radiation from Smart Meters is making the harmfulenvironmental that EHS people can’t access to their house.
Moreover, EHS people will increase more and more due to RF
radiation from Smart Meters. It might cause economical hugedamage of California. The radiation is also affect to vulnerable
people, such as children and elderly people. CCST have to stand on
precautional principle, and to recommend to replace wired metersfrom wireless Smart Meters, as soon as possible.

References;P. Levallois, .R.Neutra, G. Lee and L. Histova, Study of self reported
hypersensitivity to electromagnetic fields in California, Environ.
Health. Perspect. 110(4) (2002) 619-623
Bioinitiative Report: A rationale for a Biollogicaly-based Public
Exposure Standard for Electromagnetic Fields ( ELF and RF)

Federal Register Vo;.67, No. 170/Tuesday, September 3, 2002/ Eiles
and Regulations
National Institute of Buildings Sciences, “IEQ Indoor EnvironmentalQuality” (2005)