RAYMOND RICHARD NEUTRA M.D. Dr. PH
956 EVELYN AVENUEALBANY CALIFORNIA
94706
raymondneutra@gmail.com
January 30,2011
CCST
Dear Sirs,
Some citizens are worried about the involuntary application of wireless real time
monitoring of their electricity use. Their concerns relate to the invasion of privacy andthe addition of radio frequency (RF) electromagnetic and electric and magnetic exposuresfrom meters in their own homes and in their neighborhoods. Some have pointed out that
there are other technologies now in use in other countries that avoid the exposures.
Public officials approached you with a very narrow framing of the issue asking you:(a) if one could guarantee an absence of health effects if RF exposures were always
below current thermally based standards.
(b) If other standards were needed to deal with non-thermal health effects
You answered:
1. The FCC standard provides a currently accepted factor of safety against known
thermally induced health impacts of smart meters and other electronic devices inthe same range of RF emissions. Exposure levels from smart meters are well
below the thresholds for such effects.
2. There is no evidence that additional standards are needed to protect the publicfrom smart meters.
Your first answer doesn’t respond to the official’s first question at all, instead it states
what all parties agree to, the standard protects against thermal effects and smart meters
emit fields that are below the standard.
Your second answer is technically a falsehood. There is lots of evidence that would
suggest that RF and ELF exposures well below the current standards may be capable ofcausing added lifetime risk that exceed the benchmark which triggers health based
regulations ( 1 per hundred thousand). You could have turned your second answer into atrue statement by saying something like this:“When our panel, that included no epidemiologists, reviewed the extensive
literature, epidemiological and non epidemiological on non-thermal RF
exposures, we concluded that it is not beyond a reasonable doubt that non-thermal
exposures are capable of adding life-time risks of regulatory concern. This isbecause we would require a clear understanding of the physical induction1mechanism , the carcinogenic mechanism and toxicological and epidemiologicaleffects well above the resolution power of the studies before we would say that
non-thermal exposures can cause significant risk at the ‘beyond a reasonable
doubt level’.”A beyond a reasonable doubt standard is required in criminal proceedings andwould be inappropriate in a civil proceeding, where only a “more likely than not”
standard is required. We were all reminded of this in the famous OJ Simpson
trials.
So, what certainty standard is applicable here? How certain to we have to be of
how much risk before we move from the status quo to cheap and expensive
measures to reduce smart phone exposures? On page 24 you say “.. retrofitting
millions of smart meters with hard wired technology could be difficult and costly.
Perhaps more importantly, retrofitting smart meters would not address thesignificantly greater challenge presented by the billions of mobile phones in use
globally.”
This sentence also includes important unstated assumptions:a) If other actors are exposing you to harm more intensely than I, then I
have no moral duty to remove my less intense harm until he removeshis.
b) It would not be cost beneficial to switch to wired smart metersc) It would raise utility rates substantially to switch to wired smartmeters.
d) I have no moral duty to switch to a lower exposure meter, even if theimpact on utility bills are minimal.
I provided your staff with a link to the many projects of the California EMF Program atwww.ehib.org/emf. In it they would have found our analysis of policy issues with regardto power lines and house wiring and our extensive risk evaluation. In it we assessed theavailable options and their costs. You made no attempt to do this even in a rough way.
Then we examined what the adoption of these options would do to utility rates. You did
not do that either. Then we asked how certain we would have to be of how much added
lifetime risk of disease before it would be cost beneficial to move to the cheap andexpensive options. A certainty well below the “more likely than not” standard would
have sufficed to justify cheap options to even a hard hearted utilitarian. We also explicitly
carried out a duty ethics analysis of the situation which you did not do. In our risk
evaluation we tried to avoid the pitfalls of misleading language, such as using the phrase“no evidence” to stand for “ the evidence doesn’t convince us.” As you know this phrase
is much beloved by those who deny human influences on global climate change. Then
we avoided expressing exposures as fractions of irrelevant standards as you have done.
We avoided expressing our scientific certainty as a dichotomy between “beyond areasonable doubt” and “not beyond a reasonable doubt” as you effectively have done.
This dichotomous formulation has also been avoided in reports on the human effects in2

Global Climate Change. Finally we made explicit the rules for weighting various streamsof scientific evidence to develop our degree of certainty. You provided neither yourfactual grounds nor rules of inference for justifying your “no evidence” statement.
Expressing smart phone exposures as a fraction of the thermal standard makes it soundsmall, expressing it as a multiple of the background would make it sound alarming. Yourgraph was enough.
I said at the beginning that the public officials framed their question in a narrow way anda way that was overly focused on numerical standards as a solution to environmental andoccupational hazards. We don’t control automobile trauma with a standard, we control itwith a technical solution, seat belts, airbags and traffic rules. We don’t control the
carcinogenic risk from wood dust by a wood dust standard, we mandate dust masks andair vents. I personally don’t think we know enough about the exposure metric to set astandard at this time.
The solution to any risks of regulatory concern from PG &E’s smart meters could be toswitch to wired smart meters now and gradually replace the wireless ones if the rate
payers can live with the impact to their utility bills.
If the public officials narrowed their questions with the intent of receiving an answer
that would take this issue off their radar screen, than you have responded in a narrow way
that would serve such a purpose.
This is not the way I would like to see public policy pursued. Unfortunately you are notalone in this pattern of language use, hidden assumptions and making the uncertain seemcertain so a to provide cover for policy.
Sincerely yours

Raymond Richard Neutra MD. DrPH3