Commentary on the California Council on Science and Technology Report“Health Impacts of Radio Frequency from Smart Meters”
By Dr. Karl Maret
Dove Health Alliance, Aptos, CA
January 30, 2011
This is a commentary on the California Council on Science and Technology (CCST)report,“Health Impacts of Radio Frequency from Smart Meters” published January 2011. I submitthat the CCST report, written in response to health concerns expressed by Assembly
Members of the California Legislature, contains inaccuracies and minimizes the biologicaleffects and health impacts of non-thermal radiofrequency radiation, such as those produced
by wireless technologies including Smart Meters.
For the record, my qualifications to make this commentary are that I hold a Bachelor of
Science in Electrical Engineering, a Master of Engineering degree in Biomedical
Engineering, and a Medical Doctor degree and have additionally completed a four year postdoctoral fellowship in physiology. I have been interested in the health effects ofelectromagnetic fields (EMFs) for many years and given lectures about the potential healthimpacts of non-ionizing radiations, both in Europe and the United States. I am president of anon-profit foundation interested in energy medicine, a sub-specialty within the field ofComplementary and Alternative Medicine (CAM) as defined by the National Center for
Complementary and Alternative Medicine (NCCAM), a center within the U.S. National
Institutes of Health (NIH).
My specific concerns with the report are as follows:
1.
2.
3.
4.
5.

The minimization of the problem of non-thermal microwave radiation;
The minimization of the need for lower exposure standards;
The increase in radiation levels at potential local hotspots through reflection;
The lack of information about the impact of pulsed radiation from Smart Meters;
The lack of information on the health impacts of night-time radiation from Smart
Meters;
6. The lack of modeling or actual measurements of the contribution from Smart Meters
to the existing background microwave radiation;
7. The lack of health and environmental consideration by the CPUC when the Advanced
Metering Infrastructure (AMI) was approved.

Until these issues are more fully addressed it is recommended that the current Smart Meter
deployment using radiofrequency radiation (RFR) be halted pending a more unbiased
reassessment of the potential health issues associated with these meters, including areassessment of the Advanced Metering Infrastructure (AMI) program approved by the
California Public Utilities Commission (CPUC) without any environmental impact
assessment. Further, that the California public be offered the option to opt out of thisprogram, which at present is mandatory for every dwelling.

Page 1 of 14Maret, 2011 – Commentary on CCST Report on Smart Meters1. Minimization of Non-thermal Microwave Radiation from Smart Meters
On page 4 of the CCST report it states that “To date, scientific studies have not identified orconfirmed negative health effects from potential non-thermal impacts of RF emissions suchas those produced by existing household electronic devices or smart meters.” This finding
minimizes the extensive body of scientific research on the biological effects of non-thermal
electromagnetic fields. The biological effects of low-level, non-thermal electromagnetic
fields have been researched for over 30 years. Therespected 2007Handbook ofBiological
Effects of Electromagnetic Fields edited by Barnes and Greenebaum (1) states on page 377:
“The biophysical lore prevailing until the late 1980s and lingering to this day is that,unless the amplitude and frequencies of an applied electric field were sufficient totrigger an excitable membrane (e.g. heart pacemaker), produce tissue heating or movean ion along a field gradient, there could be no effect. …. However, this position had tobe changed as the evidence for weak (non-thermal) EMF bioeffects became
overwhelming.”
Prof. Arthur Pilla, PhD
Professor of Biomedical Engineering, Columbia University
There are numerous reports on the potential health effects of non-thermal electromagnetic
fields. Early reports include papers by Frey (1993), Lai (2000) and Hyland (2000), among
many others. An international working group has delineated many additional scientificfindings (Bioinitiative report, 2007). Special editions of the journal Pathophysiology were
specifically dedicated to this topic recently (Pathophysiology, 2009). Recently, the European
Journal of Oncology published an entire monograph entitled “Non‐Thermal Effects andMechanisms of Interaction between ElectromagneticFields and Living Matter” outlining nonthermal effects on living systems. This came from the National Institute for the Study andControl of Cancer and Environmental Diseases “Bernardino Mamazzini” (Giuliani &Soffriti,2010).
The CCST report further states that, “Without a clearer understanding of the biologicalmechanisms involved, identifying additional standards or evaluating the relative costs andbenefits of those standards cannot be determined at this time.” I strongly disagree with thisconclusion as there is now a large body of scientific literature describing several key
mechanisms for the action of weak electromagnetic fields. These include, among others:--

removal of calcium ions bound to cellular membranes, leading to their weakened
structure and changed cellular functioning
change of calcium ion leading to changes in metabolic processes in cells,
the leakage of calcium ions into neurons generating spurious action potentials,
fragmentation of DNA in cells seen through the Comet assaychanges in the blood-brain barrier in animals after microwave exposure
defined cellular stress response, including the production of heat shock proteins(HSP), that are triggeredelectromagnetically at non-thermal levels that require muchless energy than when triggered by heat (so-called thermal considerations)activation of specific genes by exposure to non-thermal electromagnetic fields leading
to gene transcriptionto form RNA, the first stage in the synthesis of proteins

Page 2 of 14Maret, 2011 – Commentary on CCST Report on Smart Meters

All these biological effects are well substantiated in the scientific literature and occurred atmuch lower exposure levels than current FCC standards, but are minimized by the CCST
report. It takes many years for definitive health effects to be substantiated beyond all shadowof doubt. Yet the evidence is accumulating that health effects will become more widespread,given sufficient time, from thescientifically researched biological responses to RFR. Until
the authors of the CCST report can clearly substantiate their conclusions that the California
population will not be adversely affected by the Smart Meter program, a precautionary
approach should have been recommended.
The European community has been more concerned about non-thermal radio frequency
radiation effects while our government has essentially stopped funding all research in thisarea (see below). The extensive REFLEX study involving research groups from sevencountries found effects on biological systems from cell phone radiation at levels 1/40th of thelevel of accepted safety guidelines promulgated by the International Commission on NonIonizing Radiation Protection (ICNIRP) (Adlkofer, 2006). This report focused on a four
year international collaborationof twelve European research groups involving in vitro studies
of non-thermal radiofrequency radiation from cell phones. Even Austrian insurancecompanies are now accepting the dangers from non-thermal electromagnetic radiation fromcell phones (AUVA Report, 2009).
Biological systems often respond in a non-linear manner and there is a large degree ofgenetic variability as to how animals or people are affected. Non-thermal EMFs might becomparable to the hazards of low levels of toxins found in the environment which can bepotent in very low levels at disrupting enzyme systems in the body, but may not be
proportionately worse at higher levels.
Dr. Richard Gautier in France offered a full description of active mechanisms for the actionof non-thermal EMFs. There are peer-reviewed scientific studies for each step of theprocesses that can lead to chronic diseases such as cancer, leukemia and neurologicaldiseases. These conditions often require longer time periods to develop and thePrecautionary Principle (see later) ought to be applied when adding new sources of
microwave radiation such as those from Smart Meters that are active night and day in ourhomes and places of work.
On page 14 of the CCST report, the statement “There is currently no definitive evidence
linking cell phone usage with increased incidence of cancer” is another misleading statementthat tends to minimize the cancer risk from cell phones. If the authors of the CCST report
had looked at other papers from the scientific literature (not mentioned in pages 38-44 of the
CCST report), they might come to different conclusions.
There is mounting evidence of various types of tumors being caused from cell phone usage
including parotid gland tumor (Czerninski, 2011), meningioma (Hardell et al., 2006),
acoustic neuroma (Sato et al. 2011), brain tumors (Hardell&Carlberg, 2009) and testiculartumors (Hardell et al., 2007), to name only some.Considering the increasing number
ofscientific papers describing various types of tumors associated with non-thermal radiationfrom cell phones that are appearing in the medical literature, it is not helpful that non-thermalradiations from Smart Meters, which might potentially add to our long-term susceptibility toserious diseases, be minimized as was done in the report.
Page 3 of 14Maret, 2011 – Commentary on CCST Report on Smart Meters2. The minimization of the need for lower exposure standards
The report states on page 8 that “…given the existing uncertainty about non-thermal effects,
there is no generally accepted, definitive, evidence-based indication that additional
standards are needed.” This statement is misleading since an international collaboration ofresearchers in this field have called for a reexamination of the current ANSI standard basedon the increasing evidence of the adverse effects of low-level electromagnetic fields (Hardelland Sage, 2008) Variousresearch groups have consistently warned that the existing
guidelines may be inadequate (Hyland, 2000; Levitt &Lai 2010;Bioinitiative Report, 2007).
Even the International Commission on Non-Ionizing Radiation Protection (ICNIRP) stated in1998 that “interpretation of several observed biological effects of electromagnetic fields isfurther complicated by the apparent existence of “windows” of response in both the power
density and frequency domains. There are no accepted models that adequately explain these
phenomena, which challenge the traditional concept of a monotonic relationship between thefield intensity and the severity of the resulting biological effects.” (ICNIRP, 1998). In otherwords, there are windows of sensitive biological response in which potential health effects
can occur at much lower exposure levels than currently mandated by the FCC standards.
Already in 1999, the federal government’sRadiofrequency Interagency Work Group(RFIAWG) had “identified certain issues thatwe believe need to be addressed to provide astrong and credible rationale to support RF exposure guidelines.” Dr. Gregory Lotz from the
Department of Health and Human Services, National Institute for Occupational Safety and
Health addressed these specific issues in a letter dated June 17, 1999 to Mr. Richard Tell,then Chair of the IEE SCC28 (SC4) Risk Assessment Work Group. Ironically, it was thissame Richard Tell Associates of Las Vegas, NV who wrote the report for PG&E describing
the apparent safe exposure limits of the Smart Meter program that was also referenced in the
CCST report (Tell, 2005; Tell, 2008).
The Tell Associates report simplified the apparent safety of the Smart Meter radiation by: 1.
Only considering a single isolated Smart Meter radiator in free space; 2.Time averaging thepulse RF radiation so that it appeared as a low level of 8.8 uW/cm2; 3. Not considering otherRF microwave emitters in the home environment; and 4. Considering only ground wave
reflections of the microwave emissions and no other reflective surfaces (see below). The
report also does not address the concerns of the federal RF Interagency Work Group
including among other concerns: 1.The biological basis for local SAR limit; 2. the selectionof an adverse effect level; 3. the nature of acute versus chronic exposure; 4. the intensity or
pulsed or frequency modulated RF exposure; and 5. the issue of time averaging. These are
critical issues which makes the issue of proper exposure guidelines a central issue in thismatter. It further casts great doubt on the conclusions of the CCST report that downplays theneed for new, lower exposure standards.
Epidemiologic evidence is a major contributor to the understanding of the potential effects of
EMF on health. The International Agency for Research on Cancer (IARC) classified EMF asa “possible human carcinogen”, or a Group 2B carcinogen; (IARC, 2002) this classification
was mostly based on consistent epidemiological evidence.Although the body of evidence isPage 4 of 14Maret, 2011 – Commentary on CCST Report on Smart Metersalways considered as a whole, based on the weight of evidence approach and incorporating
different lines of scientific enquiry, epidemiologic evidence, as most relevant, is given thegreatest weight.
Several European countries, having taken a deeper look at recent scientific data, are
beginning to follow a different approach to the RFR question. They recommend prudent
avoidance in siting cell tower antenna installations near schools, hospitals or wherever people
congregate. This approach is part of what is called the Precautionary Principle, which has
been adopted in many countries, including the U.S., for various applications in international
treaties. The Precautionary Principle holds that when questions of safety are concerned,
precautions should be taken to protect public health even if scientific data is incomplete, or
the mechanisms of action are not understood (Levitt, 2000; Kheifets et al., 2001).

3. The increase in radiation levels at potential local hotspots through reflection
Although it is true that the Smart Meters comply with current U.S. Federal Communications
Commission (FCC) guidelines because they operate below the existing power density
thresholds, power density is not the only factor determining biological effects fromradiofrequency radiation. The power density level safety standards are solely based onthermal considerations, yet it is the non-thermal radiation levels that are the key to potential
health impacts. The non-thermal effects occur at lower levels from various emitting radiators
now in common use including cell phones, cordless phones, Wi-Fi, Wi-Max, to name onlysome. Smart Meters add to this cumulative ubiquitous low-level background microwave
environment.
RFR can increase to higher levels than anticipated due to surface and ground reflections fromthe various radiators. (Hondou, 2002; Hondou et al,2006;Vermeeren et al, 2010), even atsome distance from the sources. These scientific studies suggest that reflectivity from othermetallic surfaces and reflective materials could increase the power density of the RF fields
significantly, leading to the development of hot spots in our homes. Richard Tell Associates
report commissioned by PG&E in 2005, and updated in 2008, contained calculations of theintensity of RF fields produced by the Smart Meters that included only ground reflections
estimated to increase the field strength by 1.6 times (equivalent to a 2.56-fold increase in the
power density). In light of recent scientific findings and actual computer modeling studies,
the Tell estimate of ground reflectivity may be significantly too low and does not address thedevelopment of possible hotspots in the home. If microwave hotspots occurred near sleeping
quarters or near a baby’s crib, their health impact could be highly significant. Sage
Associates report, which made some estimates of Smart Meter impacts through computermodeling, even suggests that under certain assumptions the emissions from Smart Meters andtheir local reflections might even exceed FCC standards (Sage, 2011).
The CCST report never even acknowledged the need for computer modeling to ascertain thepotential riskof higher microwave radiation levels in our homes as a result of Smart Meter
installation, alone or in interaction with other microwave emitters. We believe that suchmodeling is vital if the public is to know the potential for the developmentof hot spots insensitive living areas. The Richard Tell Associates study carried out for PG&E did notconsider other microwave sources in the environment stating, “The study does not take into
Page 5 of 14Maret, 2011 – Commentary on CCST Report on Smart Metersaccount the potential for RF fields that may be produced by other devices or systems that are
not part of the Smart Meter program upgrade. Such devices or systems include cellular
telephones, cellular telephone base stations, broadcast radio and TV stations, microwave
ovens used in the home or any other source of RF energy.”

4. The lack of information about the impact of pulsed radiation from Smart Meters
The is considerable difference between the biological impact of pulsed microwaves, as
produced by Smart Meters, compared to continuous waves, such as those produced by
microwave ovens. No distinction is made in the safety criteria between continuous andpulsed waves because of the narrow-minded focus on thermal damage alone.
Many scientific studies have pointed out that radiofrequency radiation with different
modulations and pulse characteristics produce different biological effects even though they
may produce the same pattern of different specific absorption rate distribution and tissue
heating (Levitt &Lai, 2010).
Peer-reviewed studies have shown that the differences in modulation patterns and waveforms
can produce quite different biological effects. They include the works of Arber and Lin(1985); Campisi et al (2010); Huber et al. (2002); Luukkonen et al. (2009); d’Ambrosio et al(2002), among many others. Already Soviet research in the 1960s showed that pulsed waves
induced stronger and often inhibitory biological and neurological effects than continuous
waves (Osipov, 1965). A review of the hazards to U.Smilitary personnel from highfrequency electromagnetic radiation was provided by Pollack (1967) which gives an
overview of the extensive Eastern European research in this field.
Marha (1963) described allowable intensities for frequencies above 300 MHz in
Czechoslovakia for continuous waves as 25 uW/cm2 but limited pulsed waves to only 10
uW/cm2. Note that these Czech recommended levels were considerably lower than theapproximately 600 uW/cm2 allowed for the RFR from Smart Meters operating in the low 900
MHz band mandated by the FCC based on only thermal consideration. Also not well known
in the West is the Soviet work showing the adverse effect of non-thermal pulsed microwave
radiation on cardiac rhythms in animals (Presman&Levitina, 1962).
The CCST report is misleading because it compares the Smart Meter emissions to those of
microwave ovens. Microwave ovens produce much higher power output but are notmodulated or pulsed in any way. It is imperative to understand that it is the modulation or
pulsation pattern that leads to biological effects at non-thermal power levels. Biologicallysensitive amplitude windows have been found at specific frequencies that lead to theselective release of calcium from cell membranes. However, above and below these uniquepower densities there is no observable effect. Pulses and square waves have the greatest
biological impact because they produce rapid changes in voltage across biologicalmembranes. Un-modulated carrier waves have little or no biological effect except if theirpower is sufficient high, such as in microwave ovens. Comparing the power levels between
modulated and un-modulated devices, as the CCST report does, is thus misleading.
The potential health effects from chronic exposure to pulsed, low power density level
electromagnetic fields might take several years to appear. These types of radiations produced
Page 6 of 14Maret, 2011 – Commentary on CCST Report on Smart Meters

by Smart Meters are of concern for their potential health impacts onthe electrically
hypersensitive part of the population. In Sweden, electrohypersensitivity(EHS) is an
officially recognized functional impairment; however it is not regarded as a disease(Johansson, 2006). Electrical hypersensitivity has been reported by many authors fromvarious industrialized countries over the last 20 years. The CCST report does not consider
this segment of our population at all. Yet in the United Kingdom there are excellent
resources about this condition, especially the work of Bevington (2010) containing over 700
references.
The ICNIRP, IEEE and ANSI standards that are currently in effect consider only thermal
effects of microwave radiation where the energy absorption is fairly linear and thus theprotective guidelines are logical. However these energy absorption guidelines would not beappropriate when frequency-specific amplitude windows are involved leading to adverse
biologicaleffects that can depend onmodulation patterns, pulse repetition rates, duty cycles,
and other frequency spectrum characteristics. With the current PG&E-mandated Smart
Meter program having a 20-year life expectancy, Californians will be living with potential
health impacts from this unproven technology in our homes for the next two decades.

5. The lack of information on the health impacts of night-time radiation from
Smart Meters
Another problem that was not addressed in the CCST report is potential health effect of
microwave radiation exposure during our sleep which may adversely affect our biologicaland circadian rhythms (daily physiological regulatory cycles). Smart Meters will pulseintermittently day and night and may have an adverse effect on sleep cycles. We do not use
our cellphones during sleep, yet Smart Meters will continue to emit pulsed RFR all nightlong.
Exposure to microwave/radiofrequency fields affect the neuroendocrine system causing
neuroendocrine chemical modulations and behavioral reactions. Already in 1970s it was
known that resonant absorption within the cranium may result in the focusing of energy andthe production of electromagnetic “hot spots” in the brain (Johnson & Guy, 1972).
Microwaves may disturb the critical hormonal regulatory areas including the hypothalamicpituitary axis through “low intensity” exposure. The body may elicit “different responses
relative to the timing of the exposure with respect to circadian rhythm” (Michaelson,1982).
At night, while sleeping, the body is principally in a repair mode and the exposure to
microwave radiation from Smart Meters may potentially be more damaging than exposure
during the day. It is vital that long-term exposure studiesduring the night be carried out todetermine if Smart Meter pulsed microwave radiation could have an adverse biologicaleffecton our population.
The European Commission’sScientific Committee on Emerging and Newly Identified Health
Risks report on “Health Effects of Exposure to EMF” stated that “No health effect has been
consistently demonstrated at exposure levelsbelow the ICNIRP-limits established in 1998.
However, the data base for this evaluationis limited especially for long-term low-level
exposure" (SCENIHR, 2009). In other words, we just don’t know what will be the long-term
Page 7 of 14Maret, 2011 – Commentary on CCST Report on Smart Meterseffect of consistent low level exposure of RFR such as those imposed by Smart Meters in
addition to the other microwave radiation sources now increasingly being used in our homes.

6. The lack of modeling or actual measurements of the contribution from Smart
Meters to the existing background microwave radiation
The CCST report is misleading on page 20 where it says that he exposure levels to people
living in metropolitan areas is quite low, around 0.005 uW/cm2. They base their assertions
on an outdated report fromJuly 1986 made by the U.S. Environmental Protection Agency
entitled The Radiofrequency Radiation Environment: Environmental Exposure Levels and
RF Radiation Emitting Sources, EPA 520/1-85-014. This data is totally outdated since it
reflects the situation before the modern cellular telephone networks were put in place.
Already in 2000, in Sweden, the radiofrequency and microwave radiation levels in urban
areas were approximately ten times higher than they were in the 1980s—and most of theincrease is due to wireless communications, according to Dr. YngveHamnerius of Chalmers
University of Technology in Göteborg, Sweden. Hamnerius measured radiation levels in the
30 MHz-2 GHz frequency range at 26 sites across Sweden with varying levels
ofurbanization. In cities, the median power density was 0.05 uW/cm2, with a 61% averagecontribution from GSM cell tower base stations. (Microwave News, July/August 2000). In
the U.S. we do not have any up-to-date data since the U.S. Environmental protection Agency
has not carried out any research studies for two decades. I have personally measured
background microwave radiation levels that are hundreds of times higher in many
metropolitan areas than the values described in the CCST report using 1986 EPA data.
This increasing amount of background microwave radiation has become of medical concern
in many parts of the world. For example in March 23, 2009 European scientists called for areassessment of the damaging health impacts of increasing levels of electromagnetic
radiation (Electrosensibilité : Appel des scientifiques du 23-03-2009). Similarly, in
November 2009 a meeting of international experts on the biological effects ofelectromagnetic fields met in Stavanger, Norway to discuss the unprecedented global
exposures to artificial electromagnetic fields from communication and power technologies.
Many scientists at this meeting recommended that lower limits be established forelectromagnetic fields and wireless exposures due to the health impacts at much lower
exposure levels than are now considered safe.
The United States government essentially stopped all research on RF radiation effects on theenvironment, including population exposure, in 1996. The Environmental Protection
Agency’s budget and staffing for RF radiation activities was $821,000 from 1990 to1995 andonly $25,000 between the years 1996 to 2000 (Levitt, 2000, page 271). Essentially, there
was no government money spent in the last 15 years by the EPA to fund a reexamination of
the RF exposure limits by the National Council on Radiation Protection and Measurement(NCRP). Our changing microwave environment is thus not being studied by our federal
government. If the federal government is not looking after our health concerns concerning
low level electromagnetic fields, it is imperative that utilities have their new microwave
technologies evaluated by state government research laboratories or public healthPage 8 of 14Maret, 2011 – Commentary on CCST Report on Smart Metersorganizations prior to letting this technology be deployed on a largely unaware California
public.
What is needed is an up-to-date series of measurements in dense urban environment thatmeasures the combined RFR levels from all radiating emitters and estimates or measures the
cumulative effect of Smart Meters and collectors to radiation exposure levels in homes. This
must include all RFR emitters that are connected to the MESH and home area networks(HAN) as deployed by PG&E. Only independent assessments or measurements of theseradiation levels ought to be considered, not those conducted by companies that have direct orindirect connection to the utilities. Until these studies are available, it is recommended that
the Precautionary Principle be adopted.

7. The lack of health and environmental consideration by the CPUC when the
Advanced Metering Infrastructure (AMI) was approved.
On July 20, 2006, the California Public Utilities Commission (CPUC) issued their final
opinion, Decision 06-07-027, authorizing Pacific Gas and Electric to deploy an Advanced
Metering Infrastructure (AMI) that would lead to the automation of 5.1 million electric
meters and 4.2 million gas meters. The CPUC decision was in response to PG&E’s
application 05-06-028 filed on July 16, 2005. In Section 7 (Technology) of this CPUC
decision, the AMI deployment was described as using Power Line Carrier technology forelectric meters and a fixed network system with radio frequency communications channels
owned by PG&E for gas meters. The system was to have a useful life of 20 years. In section
15 (Environmental Review) of the Decision, it stated that there is no need for an analysis of
PG&E’s AMI deployment pursuant to the requirements of the California Environmental
Quality Act (CEQA). It appeared that due to the suggested Power Line Carrier technology tobe employed, the health or environmental effects were not considered at the time and the
CPUC felt under no legal obligation to undertake any environmental review before approving
the PG&E application.
On March 12, 2009, the CPUC made another Decision 09-03-026 in response to PG&E’s
application A.07-12-009 filed on December 12, 2007 to expand the AMI programsignificantly. Now the CPUC approved the establishment of microwave mesh networks aswell as incorporating a Home Area Network (HAN) gateway deviceinto advanced electric
meters to support in-home HANapplications; and upgrading PG&E’s electric meters to solidstate meters,now called Smart Meters. In this decision, which conveniently expanded its
2006 AMI deployment decision, there was absolutely no mention of any environmental or
health impact even though a whole new radiofrequency technology infrastructure was now
approved for deployment on every home and business in California. We believe that thisdecision represents a gross degree of negligence by the CPUC in protecting the health andsafety of the citizens of California. The CPUC needs to readdress the health and safetyissues directly and immediately halt the installation of the Smart Meter program pending
clarification of the issues raised by many scientific investigators who have commented on theinadequacy of the CCST report.

Page 9 of 14Maret, 2011 – Commentary on CCST Report on Smart Meters

Conclusions
The time needed for a new technology to be developed and rolled out is much shorter than
the time needed for research to investigate the possible health effects on the general
population. The current Advanced Metering Infrastructure using microwaves in the 900
MHz frequency spectrum approved by the CPUC is going to adversely impact the physiology
and ultimately the health of many Californians over the next twenty years, the anticipated life
time of the Smart Meters now being deployed. This program is being implemented without
widespread public knowledge or approval and without the specific informed consent inwriting from every household.
Already the most sensitive members of our society, those who are especially vulnerable bybeing electrically hypersensitive, are registering health complaints such as headaches, sleep
disturbances, cognitive difficulties, dizziness, heart palpitations, to name only a few. Most ofthese symptoms could also be related to other medical conditions making it difficult toascribe their appearance specifically to the Smart Meters radiation directly. Although not yet
recognized in this country as a state of physiological imbalance, hypersensitivity of humansubjects to exposure to electric and magnetic fields has been reported for over 20 years bymany authors in many industrialized countries. If only 1% of California’s population were toreport symptoms of electrical hypersensitivity after Smart Meter installation, over 370,000
people might be adversely affected by RFR.
The dissemination of this Smart Meter technology could have been accomplished without
using radiofrequency radiation by using much safer power line, fiber optic or telephone
communications technology. For example, a Smart Meter power line communications
technology was used by Italian utilities in 27 million households using meters designed in
California. In the Netherlands, the population concerned about the security and health issuesof Smart Meters was given the options to opt out from having the meters installed.
Californians were never given this option. Yet this AMI program, costing utility customers
over $2 billion, represents the largest technology roll-out in the history of Pacific Gas andElectric. Ironically, it is being financed by the rate payers without their direct consent.
This program represents an epidemiological experiment involving our unsuspecting
population whose outcome will only be fully known after many years exposure. It is being
shepherded through the regulatory process by the CPUC who has not seen fit to study thepossible adverse health impacts of this technology before approving its usage. It has nevershown any willingness to seriously consider the well-documented non-thermal effects ofpulsed microwaves on living systems and will undoubtedly use the misleading CCST reportto avoid any questions about future health implications of this technology. Because of theuncertainties of adverse long-term health impacts, the CCST ought to have recommended
that a Precautionary Principle be invoked that would allow more time to directly study theeffect of this pulsed radiation with both in vitro and in vivo testing in realistic settings of themesh network, especially in high density Smart Meter environments in our cities.
Additionally, in cities the Subterranean Network Deployment System (SUNDS) is now also
being installed by PG&E. This will add even higher microwave exposure levels to thegeneral population. Any description of this new system was conspicuously absent from the
CCST report. At a minimum, the utilities and CCST ought to have carried out extensive
Page 10 of 14Maret, 2011 – Commentary on CCST Report on Smart Meterscomputer modeling to assess the impact of Smart Meter technology in realistic settings,
taking into account the other wireless technologies have already been deployed and whichhave significantly increased the background microwave exposure of the population over thelast 20 years.
In summary, we find that the CCST report is incomplete and misleading giving California
State regulators a false sense of security while potentially endangering the future health andwell-being of Californians. It is requested that the current Smart Meter deployment be halted
pending a more comprehensive scientific investigation of the biological response and healthimpacts of the non-thermal aspects of this technology. All households should be offered full
disclosure about possible exposure levels, modulation patterns, peak power levels andinteractions with other parts of the microwave spectrum in their home environments.
Additionally, those who are sensitive to this radiation must be given the choice to opt out
from having this form of RFR imposed upon their residential dwellings.

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