To Lora Lee Martin:
Critique of CCST's report, "Health Impacts of Radio Frequency from Smart
Meters,"From: Samuel Milham MD, MPH
82181 Bergman Dr
Indio CA 92201
Dear Ms. Martin,
My name is Samuel Milham. I am a physician /epidemiologist , specializing
in occupational medicine and in the health effects of electromagnetic fields (EMF).
I was the first to document the link between occupational electromagnetic field
exposure and cancer. My website www.sammilham.com has links to my recentpapers, to my CV and to my new book, Dirty Electricity which presents evidence
that most of the so-called diseases of civilization are due to EMF exposure notlifestyle.
Your report, unfortunately, reads as if were written by PG and E or Edison,and pays no attention at all to a very important EMF exposure variable, dirty
electricity (high frequency voltage transients and harmonics).
Smart meters transmit their data via radio frequency (RF) either through theair or on utility wiring. The electronics of all transmitters operate on direct current(DC), which is obtained using inverters and switching power supplies in the meter
which interrupt the grid AC current flow and generate dirty electricity which flows
back to the grid on the 60 Hz AC throughout the substation service area.
Interrupting current flow generates dirty electricity. Stetzer Electric markets aplug- in meter which measures dV/dT, the average rate of change of voltage on thewiring between 2 and 100 KHz, and capacitive filters to reduce the dirty electricity
levels.
The grid was originally built so that all the electricity which flowed from thesubstation returned through the neutral wires. When people started using
computers and other electrical devices with non-linear loads, the existing neutrals
couldn’t handle the loads and fires resulted. The electrical building codes wererevised to require more robust in- building neutrals, but the utilities got off thehook by instead of beefing up their neutrals, they simply tied the neutrals to theearth so that now, about 70% of the electricity delivered from the substation ,returns there via the ground. The California PUC rule 33.2 forbids using the earth

for return currents, but this didn’t stop PG and E or Edison from running wiresdown every other power pole connecting the neutral to the earth. Here is the PUC
rule: (the bold font is mine)

General Order 95
Section III
Requirements for All Lines
33.2

Ground or Earth as a Conductor
Ground or earth shall not be used as a normal return or circuit conductor. In
direct current supply systems or in single phase or polyphase supply systems, aneutral or any other conductor shall be used under normal use as a return or

the grounding of the neutral or
any other conductor is not permitted as anormal return or circuit conductor. The neutral or anycircuit conductor; however,other conductor is permitted to be grounded only for the purposes ofstabilization and protection.
Note:

Revised January 19, 1994 by Resolution SU–25.

Violation of this rule has created health problems in farm animals and families, anddirty electricity gets into our homes and offices and schoolsvia ground rods andelectrically conductive plumbing. I have measured higher EMFs in homes with theelectrical service turned off due to unbalanced current flow.
In the last few weeks, I have been contacted by two electrohypersensitive
California women, both of whom had to move out of their homes because of illness
as smart meters were being introduced into their neighborhoods, before smart
meters were attached to their homes. A third east coast woman sent me an
oscilloscope wave form obtained in her home with the electrical service turned off
and no smart meter on her house. The neighborhood had smart meters deployedwhich used utility wiring to submit information to the substation. The frequency of
the wave form was exactly that used to transmit smart meter information. (I’llprovide names and contact information on request). In the California cases theresidences were too far from the transmitting smart meters to be affected by theRF. I believe that in all three cases, the damaging signal was dirty electricity in thewiring and the ground currents coming from the deployed meters.

My hypothesis is easy enough to test. Dirty electricity levels measured inhomes, offices and schools should increase after the meters are deployed. Dirty
electricity levels measured in the utility drops and in the earth will also increase as
the meters are deployed. Since dirty electricity is a potent carcinogen (see attachedpaper and pp. 78-80 in my book), and causes numerous health problems, the only
way to avoid a public health catastrophe is to send the smart meter information
over existing telephone land lines or go back to the analog meters. I’m not making
light of or ignoring the RF pollution caused by the smart meters, but think the dirty
electricity may be a more serious and intractable problem.
My contact information is available on my website.
Respectfully, Sam Milham MD, MPH