January 17, 2011
Susan Hackwood, PhD
Executive Director
California Council on Science and Technology
Lora Lee Martin, Director
Strategic Policy Initiatives and Government Affairs
California Council on Science and Technology
Subject:

Letter of Comment on Smart Meter Report

This letter addresses the CCST Smart Meter Report issued on January 11, 2011. Overall,
the report does begin to highlight international scientific concerns about chronic, lowintensity radiofrequency radiation exposures. Radiofrequency radiation health risks havebeen and continue to be addressed by scientific bodies around the world as a credible
threat to health. 1-4The Report text provides an introduction to the science and public health questions onhealth impacts that can reasonably be expected from chronic exposure to low levels of RF
in close proximity to occupied space in homes, schools and other daily living
environments.
Conclusions Are Not Supported by Evidence of Compliance with FCC Safety Limits
There is no solid basis in the CCST report to conclude (or to support the contention) thatFCC public safety limits are met for smart meters, in the manner installed and operated.
Conclusions Disregard Evidence in the Report for Possible Health RiskThe text of the report only partially documents potential health risks from low-level,
chronic exposure to radiofrequency radiation. The conclusions ignore this discussion.
Conclusions Do Not Follow from Report
Conclusions of the report are inconsistent with the report’s more balanced warnings about
possible risks to health. The overall legitimacy of the report is cast into doubt as a result.
CCST’s report could equally well have concluded ‘there is ample evidence to advise theCalifornia Legislature that, based on multiple studies of radiofrequency radiation below
current FCC safety limits, it is advisable to issue a cautionary warning on the wirelesscomponent of smart meters until a full assessment of their effects is completed by	  1	  independent experts. Further, it can be concluded that the continued rollout of wirelesssmart meters may increase public health risks on a widespread basis and should bereconsidered in light of the existing scientific evidence and public health warnings forsuch chronic exposures to pulsed RF.’I was one of the expert reviewers invited by CCST to submit comments for theCommittee. CCST asked several experts to answer two questions (see below). Since
the Report conclusions apparently ignored much of the expert and committee input – onlyintervention by the final editor(s) to disregard key evidence explains how CCST’s final
conclusions could give rise to the “all clear” message.
Questions asked of Invited Expert Reviewers1)	  Are	  the	  current	  FCC	  standards	  for	  smart	  meters	  sufficiently	  protective	  of	  public	  health,	  taking	  into	  account	  current	  exposure	  levels	  to	  radiofrequency	  (RF)	  and	  electromagnetic	  fields?	  
2)	  	  Are	  additional	  technology-­specific	  standards	  needed	  for	  smart	  meters	  and	  other	  devices	  that	  are	  commonly	  found	  in	  and	  around	  homes,	  to	  ensure	  adequate	  protection	  from	  adverse	  health	  effects?	  	  	  CCST Report Conclusions
1) “The FCC standard provides a currently accepted factor of safety against
known thermally induced health impacts of smart meters and other electronic
devices in the same range as RF emissions. Exposure levels from smart meters
are well below the thresholds for such effects.”
This conclusion presents a partial response to Question 1 – only that the FCCs
thermal standards are adequate (these standards prevent only heating and burningof tissues, and shock hazard, however). The conclusion does not address nonthermal (or low-intensity) RF exposures, which is really the point. It also issilent on FCC violations of public safety limits, which have been calculated tooccur.132) “There is no evidence that additional standards are needed to protect thepublic from smart meters.”
By ignoring evidence for low-intensity RF adverse health effects, the Reportessentially then dismissed the need for changes in public safety standards forpulsed RF. This conclusion simply cannot be reconciled with the evidence
presented in the report (thin as it is), nor with the larger body of evidence known
to experts in this field. That evidence is now widely discussed by international
health and safety experts who find the existing thermal standards inadequate toprotect public health. 1,2	  2	  FCC Violations and Excessively High RF Exposures are Ignored
Another report issued on January 1, 201is titled Assessment of RadiofrequencyMicrowave Radiation Emissions from Smart Meters by Sage Associates.13 It documents
what RF levels may be expected. The Assessment seems not to have been consideredeither by the CCST experts nor the Committee.
The Assessment identified where and under what conditions smart meters can cause FCC
violations of public safety limits as the meters are typically installed and operated. TheCCST report concludes that all smart meter RF exposures will be well below the FCC
safety limits, and this is erroneous.
To date, there have been no other studies that provide sufficient information to supportthe claim that smart meters comply with FCC regulations. In fact, there is solid evidence
from a review of the FCC Grants of Authorization and attached FCC RF exposure studies
that many thousands (perhaps millions) of meters are in clear violation of one or more of
the explicit limitations noted on each FCC Grant of Authorization. The FCC Grants ofAuthorization are void unless meters are installed in compliance with every one of thoselimitations.
The Assessment also shows many cases where, although the FCC safety limits may not
be violated, excessively high RF levels from smart meters would be predicted to occur
within the home or in other occupied space. In many instances, predicted RF levels aremany times higher than those reported to cause adverse health effects. 5-12
Such exposures, if chronic, would reasonably be expected to result in increased diseaseand disability.
Misleading Comparisons Are Made to Cell Phones
CCST’s report makes misleading comparisons of RF exposures from cell phone use andfrom smart meters, an apparent effort to minimize public health concern. If the FCC had
thought smart meters would be held to the head in normal operation, they would haverequired smart meters to be tested for SAR compliance, not power density. These are not
the same, and to compare them is wrong.
Cell phones produce a high, localized RF exposure at the head. They are presumed to be
used within 20 centimeters (8”) of the body. Smart meters, like cell towers, create wholebody exposure rather than localized exposure in most circumstances, and specific FCC
compliance depends on keeping a 20 cm or greater distance from the meter. Cell phone
use is voluntary; smart meter exposure is involuntary. Cell phone use is sporadic orintermittent, but smart meter exposure estimates are ‘all over the map’. There is great
uncertainty on this point, and as such, the outcome cannot be known; therefore, noassertion of safety or compliance can be given.	  

3	  RF Levels from Smart Meters are Unreconciled and Need Assessment
PG&E’s sole figure for RF exposure was given during CPUC proceedings as 1/6000th of
the federal health (sic) limit. Nothing is given about the specific conditions under which
this estimate might be true (antenna make and model, duty cycle, which FCC formula,what reflection factor, one meter or multiples, etc). However, from that single data point,
we calculate that RF exposure to be 0.11 uW/cm2 at 10 feet (where the FCC safety limit
is known to be 655 uW/cm2 at the frequencies 915 MHz and 2405 MHz). This meansthat at 10 feet from the meter, PG&E says the RF level will be 0.11 uW/cm2.
Kundi and Hutter (Pathophysiology, 2009)2 say they don’t yet find RF health impacts atlevels below 0.05 to 0.1 uW/cm2” but do find consistent evidence of adverse healthimpacts at levels generally above that (based on at least eight cell tower studies
conducted internationally). These figures were for healthy adult populations.
From the CCST Report, figures 1 and 7 (identical) give a comparison of RF levels fromvarious sources, including two estimates for smart meters. They are 4 uW/cm2 at 10 feet,and 40 uW/cm2 at 3 feet away (no source is identified for these estimates, and again, theoperational conditions are unspecified). Another estimate from CCST’s report (pages 17and 22) says that a ‘worst case’ RF estimate – a meter that transmits continuously –would produce 60% of the FCC limit (which is 655 uW/cm2 for the combined antennafrequencies), or 393 uW/cm2. However, the location at which this RF exposure level iscalculated to occur is not given. The information is not useful. But, given the peerreviewed scientific literature, any of these estimates is too high for chronic exposure topulsed RF. 1,2
No one can reconcile or separate reasonable from unreasonable RF predictions withoutsome better, more systematic computer modeling of RF exposures.
Cumulative RF is Not Assessed Prior to Meter Installation
None of the PG&E or the EPRI estimates includes any provision for ‘what amount of RF
exists already’ and does the smart meter’s additional RF burden push that location overthe FCC limit. The CCST report does not consider cumulative sources of RF (WI-FI,
nearby cell tower(s), AM, FM, TV, HAM transmitters, etc). The cumulative RF burdenmust be considered, including ongoing RF exposures from existing sources.
Further, since these meters are part of a radiofrequency surveillance and communications
system that includes cell antennas (to relay RF signals to the utility) and eventually,
power transmitters on/within appliances (to relay RF signals within the home to the smart
meter), these critical omissions in the overall RF burden placed on people from the ‘smart
meter program’ should be assessed. No one can install a smart meter and make a blanket
assertion the environment still complies with public safety standards in the after
condition, if the before condition is not known. RF exposures from multiple sources areadditive.	  

4	  Recommendations to CCST1) Advise the California Legislature that further assessment of smart meter impacts
to public health and safety are necessary before further deployment.
2) Recommend de-activation of wireless transmitters in meters already installed
pending further review.
3) Recommend that California Legislative hearings be scheduled on smart meters.
4) Post in their entirety each of the written expert review letters to CCST.
5) Recommend that the California Department Public Health receive and log smart
meter health complaints.

Thank you for the opportunity to comment on the CCST draft report on smart meters.

Cindy Sage, MASage Associates
Co-Editor, BioInitiative Report
Research Fellow, Department of Oncology
Orebro University Hospital, Orebro, SwedenReferences
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