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April 2012 Comment: D Eisenburg

April 2012 Comment: D Eisenburg

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David 1. Collins, Executive Secretary, Maryland Public Service Commission William DOnald Schaefer Tower 6 St.

Paul Street, 16th Floor Baltimore, Maryland 21202

April 4, 2012
Dear Commissioners: There are numerous authoritative scientific statements being made by unbiased experts and organizations telling us, in no uncertain terms, that the effects of radio frequency radiation such as is generated by Smart Meters, are dangerous. Organizations and experts such as those you will see cited below do not make rash, uninvestigated comments. Their official statements are wen considered and made only after serious and broad investigation into the peer-reviewed science. Responsible public officialsas well as all other individuals must surely ask~ why are all 511181t meters? Why would they do this? After all, they have rio bias, unlike industry funded "experts" and industry funded "studies .. There is no financial or other gain for these organizations in either " supporting or opposing Smart Meters.

of these important world bodies warning us of the dangers of

Testimony of Global and Public Organizations and Unbiased Medical Authorities:
The Warid Health Organization, for example, ill Press Release No. 208, on May 31st of20 11, placed the kind of wireless, non-ionizing radiation that is generated by Smart Meters and other devices into the Category 2B carcinogen list. IIltp:/ Iwww.scribd.com/doc/61286259/Radiofreg uency~ R1diation-2B-Cs."cin ogenWHO-Press-Release-No-208-5-31-11 The Karolinska Institute is one of Europe's Jeading medical universities that appoints the laureates for the Nobel Prize in Medicine and one of the top medical research institutions in the world. It recently issued a global health warning 011 wireless Smart Meter.s and is urging a halt to their rollout. bttp: Ilwww.scribd.comJdoc/48148346fKa.·oli liska-Institute-- Pl'ess- Release The American Academy of EnviroomentaJ Medicine has in January of this year, 2012, adopted a resolution calling for a halt to wireless smart meters, saying that continuing with Smart Meter installation would be "extremely irresponsible". This represents the first national physician's group to look in-depth at wireless health risks and to advise the

public and decision-makers about preventative public health actions that are necessary.

http://ppjg.meltag/american-academy-of-envi.·onmental-sciellcel The National Institute of Health, In February of 2011, warned that biological changes
in the brain occur after only minutes of exposure to the same kind of non-ionizing radiation that is emitted by Smart meters: http://jama.ama-

assn.org/content/30S/S/80S.abstract The California State Santa Cruz County Public Health Department bas recently
concluded in its official report that Smart Meters DO pose a health risk. Certainly the commissioners realize that a municipal public health department does not come to such concl usien s wi thout scientific and medi cal j ustifi cation, The Santa Cruz County, CA Board of Supervisors directed its public health officer to prepare an analysis of the research on the health effects of Smart Meters in December 2011. Poki Stewart Namkung, M.D. M.P.H., prepared this report: Health Risks Associated With Smal1Meters which recognizes: • • Smart Meters transmit pulsed radiation (RF) 24/7 There are evidence-based health risks ofRF RF exposure can be cumulative and additive The massive increase in RF public exposures since the mid-1990's The controversy between independent and industry science, including lack of funding for independent research Evidence to support an Electrical Sensitivity (EHS) diagnosis The public health issue is that Smart Meters are involuntary RF exposures FCC thermal guidelines are irrelevant for non-thermal public exposures. The lack of relevant safety standards for chronic pulsed RF

The report summary calls tor more government vigilance towards involuntary RF public exposures because, " ... governmental agencies are the only defense against such involuntary exposure." The report also provides examples of strategies to reduce RF including minimize cell and cordless phone use, use speakerphone when possible, use wired internet connections, avoid setting a laptop on your lap, and more.

Excerpts from tbe State of'California Santa Cruz Health Dept. Report:
"The public health issue of concern in regard to Smartsdeters is the involuntary exposure a/individuals and households to electromagneticfield (EMF) radiation. "

"There are numerous situations in which the distance between the Smartlvleters and
humans is Less than three feel on an ongoing basis. e.g. a SmartMeter mounted on the


external wall {a a bedroom with the bed placed adjacentto thai mounting next to the

internal wall...


•....Smart Meters emil frequencies almost continuously, day and "light,.seven days a

". .. exposure is additive and consumers may have already increased their exposures to radiofrequency radiation in the. home through the voluntary use of wireless devices .. 11 would be impossible to know how close a consumer migh: be to their limit, making uncertainty with the installation of a mandatory SmartMefer. " ".....all available. peer-reviewed, scientific research data can be extrapolated to apply /0 Smartsdeters, taking- into consideration the magnitude and the intensity ~ltheexposure. " "Since the mid-1990's the 'use qf cellular and wireless devices has increased exponentiailyexposing the public to massively increased levels of RF ., " It must he noted that there is ltttle basic sciencefundingfor is largely funded by industry. " this type ofresearch and it

"...most research carried out by independent non-govemment or non-industry affiliated researchers suggests potentially serious effects from many non-ionizing radiation exposures, researchfunded by industry and some governments seems to cast doubt on the potential far harm. " "Despite this controversy, evidence is accumulatingon the results of exposure to RF at non-thermal levels including increased permeability a/the blood-brain barrier in the head CEherhardl, 2008), harmftd t4t/'ectson sperm, double strand breaksin DNA which could lead to cancer genesis (Phillips, 2011). stress gene activation indicating an exposure to a toxin (Blank, 2011), and alterations in brain glucose' metabolism (Volkow,
2011). "

di .' lagl1os1s -_. "

"01rren tiy, research has


objective evidence

(0 support

the EHS

"Meeting the current FCCguideltnes only assures thai aile should not have heal damage from Smartidete« exposure. It says nothing about safety.from the risk of many chronic diseases that the public is most concerned about such as cancer; miscarriage, birth defects, semen quality, autoimmune diseases, etc. Therefore, when it comes to nonthermal effects oj RF, FCC guidelines are irrelevant and cannot be used/or any claims of Smanideter safety unless heal damage is involved (Li, 201/). " .'There are no current, relevant public sqfelY standards forpulsed RF involving chronic exposure of the public, nor ofsensitive populations, nor of people with metal and medical


implants that can be effected both by localized heating and by electromagnetic interference (ElVO)j01' medical wireless implanted devices. "

other countries have significantly lower RFINfW exposure standards ranging from 0.001 to 50 -W/cm2 as compared with the US guideline ql200~1 (JOO -W/cm211

"In summary, there is no scientific data fa determine
I'egardfng its non-thermal effects. "

if there

is a safe RF exposure level

This is an excellent report and a must read for all public policy decision makers, and especially utility regulators, Dr. David O. Carpenter is the Harvard medical school educated director of the (nstitute for Health and the Environment at the University at Albany, State University of New York. He says that "Smart Meters result in a significant increase of exposure to a form of radiation already shown to cause cancer and other diseases. " www.thehealthyhomeeconomist.com/ltar.Vard-Dledical~doctol"-Wat'DS



Karl Maret is a physician and eleetrleal and. biomedical engineer. He is a leading national expert on the engineering and health aspects of smart meters who also warns that we will all be at greater risk for cancer, neurological disease, and reproductive and developmental impairments from this kind ofradiation in a presentation entitled The Truth About Smart Meters: bttp:llwww.youtube.com/watcb?v=p-nmaYU6h:ek (Begins at 23:44 minutes.)

Utility Claims:
The utilities say that Smart Meters only transmit a certain number of seconds or minutes per day. But the experts say that is true only for the transmission of data on a particular home. What the utilities prefer not to admit is that smart meters must continuously communicate with neighboring meters and data collection points, 24/7, for the entire home area neighborhood mesh network to operate. Smart Meters cannot be turned off and they generate radiation continuously according to Dr. Carpenter, Dr Maret and numerous other scientific experts. Utilities claim that each burst from a Smart Meter is so short that altogether, they add up to something in the order of only 45-62 seconds per day, But this is deceptive, If a Smart Meter is transmitting anywhere from once in every 6-8 seconds to several times per second, people are being bombarded with radiation bursts constantly. Consider this companson:


1 have a gun and I shoot you with it every few seconds. 2417. Then r tell you that each shot fired is merely fractions of a second long and that if I add up all the time that I'm actually shooting at you. it comes to less than a minute per day in total, so I can't see what you're complaining about!'

Utilities claim that radiation emitted from Smart Meters is akin to a cell phone, Win, or other common household appliances. But according to radiation scientist and nuclear policy expert Daniel Hirsch at University of California, Santa Cruz, the radiation from Smart Meters is at least JOO times the whole body radiation of a cell phone (except of course, continuous and without our having a choice.) http://stopsmartmeters.org/2011/04/20/danje]-hil'Sch-on~ccsts-fuzzy-mathl
Moreover, the State of California Santa Cruz County Public Health Report very clearly demonstrates that given the variety of situations, meters, and distances people can be from Smart Meters, the reality is that they are being exposed to anywhere from 50 to 450 times the whole body radiation ofa cell phone! They made the radiation units comparable 'and underscored that the most relevant exposure is in regard to whole body radiation exposure. To further understand this: It may be true that a cell phone held to the ear radiates the EAR more than a smart meter some feet away from the ear radiates that ear. But this is not the relevant comparison. Why not? Well would you rather have a 3rd degree burn on a tiny part of your body, or 1st and 2nd degree burns aU over your body? A tilly 3rd degree burn is a much smaller health problem than Ist and 2nd degree burns all over the body, Industry claims Smart Meters meet FCC regulations and tries to thereby justify Smart Meter exposures. But experts are telling us that these regualtions and FCC public safety limits are antiquated and inadequate. Experts tell us that tissue heating is actually of no relevance here. Health harm from chronic, low-intensity exposure to smart meters in the manner installed and operated in hundreds of thousands (if not millions) of residences would be due to nonthermal (low-intensity) exposures that are chronic - not acute exposures that are very short term. This also ignores the evidence that FCC Maximum Permissible Exposure for localized exposure (peak exposure) are also likely violated since there is no adequate way to mandate separation distances for the public.

In the past scientists and engineers developed exposure standards for electromagnetic radiation based on what we now believe are faulty assumptions that the right way to measure how much non-ionizing energy humans can tolerate (how much exposure) without harm is to measure only the heating of tissue or induced currents 'in the body. In the last few decades, it bas been established beyond any reasonable doubt that bio effects and some adverse health effects occur at far lower levels ofRF and ELF exposure where
no heating (Of induced currents) occurs at all; some effects are shown to occur at several hundred thousand times below the existing public safety limits where heating is an impossibility.


For further information, see comments by Cindy Sage: http://stopsmar1metersi rvine.com/2011 111128/cindy-sage-says-smlu1-m meeting-fcc Excerpts form Cindy Sage:


On the Dangel'S to the Public, especially Children, who play at home and in theiryards, Sage: wri tes: "What 1'5 most concern i1'lg is thut thes« meters oon be.accessible direotly at and near the
face plate oj the meter, so that the public cannot be restricted {theee are

private property

and all

areas around the meter Q1'eprivate plY)perty that can be assumed to controllable

be accessible by both children

and adults). SUc1l access virrually guarantees that:violations will occur. Access is nat a situation eince these mebp:s Ol'crmpl'ioote.property ojeum-y ,-atepaym', and accessible to

the genel'al public, including children playing in their baooJul'ds, side YllI'ds,

inside tl1et'1' home!.•.•

the-FCChas no way to preuent harmfut exposures (those which exoeedfedercd safety limits as defined by the FCC).J,Sage's Recommendation: "Deploying millions ofwil-eless llhHty mei'ers on such. limited testing and ql(estionable assertions of safety is unwise. Given that RF IlO,5 recently been classified as a Possible Human Carcinogen, and this wireless utility meter initiative imposes the 111o.<;t extensive RF blanket yet created over evruy living resident: that is electrified, ratepayers and the deDision-makrti\~ wiU 11M knoiu what" irretrieuable conun itmenis oj health and l'esOW'OOS have been made until it is too late. W1lel'e euen the best industru study cannot' give more reliable and defensible evidence of compliance with FCC sajety limits, public utility commissions should halt tile rollout, pending demonstration that RF em issions meet FCC publicsafeh) limits under a reasonable lIJorst"case assessment as determined by FCC OET6sfnrm u las. "

Utility Confessions:
Pacific Gas & Electric admitted that the average number of RF pulses for their electric meters would be about 1O~OOO, meter, per day with a maximum number of over per 190,000. That's very different from their initial assertions which ranged anywhere from every hour to every 4 to 6 hours to only 2% Of 4% of the time. And a full90% of these pulses are fOT the mesh network maintenance (signals bouncing from home to home) but onLy 6 of those pulses are for reading the meter data! This doesn't include Home Area Network transmissions. This means R.F emissions of high spiking peaks from between every 9 seconds to every half second per day, 2417. http://emfsafetvnetworlLorgl?p=6030 How about peak power figures? The PG&E electric mete r transmits at 900MHz with 1 wattef transmit power. It has an antennae gain 4.0 dBi. fO.I' a peak level power of 2.5 watts, Thai' . two and a half times more than their safety data Slated. http://emfsafetynetwork.ol·gJ?p=-6030


But let's take a look at recent events closer to home. To the best of my knowledge, this is what happened: On Thursday, March l Sth, P~PCO (The Potomac Electric Power Company) conducted a, meter test on a Smart Meter. This was a refereed meter test which was witnessed by a member of the staff of the Public Service Commission (PSC). The PSC website states in the "Have a Utility Concern" section: Q. I do 110t believe my meter' is accurate. Wbat can I do about this'! A. 111the case of an electric or natural gas meter, a consumer may request a refereed meter test, which is witnessed by a Commission staff and engineer, Requests for a refereed meter test can be made through the Office of Consumer Services at 202-626~ 5120." The General Counsel of the PSC suggested to the homeowner that this test be done when it was explained to him that a telit of the meter had registered 50 to 75 high EMF (electro magnetic field) pulses in two minutes or an average of34,OOO to 56,000 or more per day. A video of the homeowners test is here: bttp://vimeo.com/36960439. ThePSC staff member took a video of the PEPCO meter test.

The PEPCO technician who conducted the test stated that the me er was ill fact sending out thousands of pulses per day and that the PEPCO website which states that "smart" meters are broadcasting six.times per day and are asleep 99 percent of tile time was in error. The other three PEPCO employees present agreed with this statement. The PEPCO technician said that the data on the website is what the manufacturer of the meter had, told PBPCO.
Yet the PEPeo website offered, at least at that time, the following, in response to t.his question: "How many times a day does tbe meter broadcast?" "Rather than continuous output, meters are idle most of the time, only waking up periodically - up to six times a day - to send a brief transmission before going back to sleep. An individual meter on a home is idle well more than 99% of the time." IIUp:1Iwww .. epco.com/res! dOCUDl en ls/s m artmetel"Sfagpep cowebsite.od f p If there is going to be an informed debate about "smart" meters it is important for uti]ities to admit how "smart" meters actually work. It is my understanding that PEPCO actually presented this information at public meetings and when questions about "smart" meter and EMF safety had been asked.


Utilities sometimes cite the California Council on Science and Technology document. But according to Dr. Daniel Hirsch ofUCSC, referenced above, this was not an independent study at all. He explains why at: http://stop8 rna rtmeters.org/20 11I04/20/daniel~hif'sch-on-ccsts-fuzzyrna th/ There are several rebuttals of this faulty, decidedly NOT independent report: See http://sagerepo rts.com/smart-rneter-rfl? p=368 and www.w4ar.com/Study Havas-Report-CCST-Smart-Meters.pdf

Both DL Carpenter and Dr. Maret have rebutted the industry assertion that there have been studies conducted that show smart meters don't pose health risks. They say that this is totally false and that to the best of their knowledge, there have been no studies on the health effects of smart meters. The truth is that no utility has ever tested these meters in the communities where they are deployed and emitting radiation tens of thousands of time per day. This alone should be reason enougb to end the smart meter program. Many of the tests on the kind of non-ionizing radiation emitted by Smart Meters have been done using instruments other than smart meters simply because smart meters have only been in people's homes for a very short time. Suggestinghowever, that here is no proof that Smart Meters cause harm is something like saying that we know the bullets from our old blue guns. are harmful. But we can't prove that the same kind of bullets from our newly minted and more powerful red gu11S are also harmful. It is incumbent upon the commissioners and all public officials to familiarize themselves

with the growing body of evidence emerging telling us tbat "smart" meters may be

causing severe illness in some homeowners and electrical problems including fires. h Up :lima rv landsmartmeterawru'tness.orgl a rticJes/inciden ts-of-fires/ & http://sto psma rim eters.o "g/2012/0 1I20/metel"S~that-endanger-shocking-d eta ils..froma-whistleblowerDand bttu:/leon3emtblog, " eiJ? 0;:::724. l The following article from March] 9, 20 J 2 raises important concerns: hUp://www.non-toxicnurse.com/the.-dangers-of-sma •• t-metel"s-hit-bomel Links for more information on EMF; http://www.tidtilhandling.dklmodigmor/ (DNA / genetic Damage to Children, fetuses and eggs of girls and to whole tine of ofT-spring - page down to last video, as one video segment ends another will load in a few seconds),


b Up :llwww.natU1.e.com/srep/2012/120315/srep00312/fuH/srep00312.htmIFetn I Radiofrequency Radiation. Exposure From 800~1900 Mhz-Rated Cellular Telephones Affects Neurodevelopment and Behavior in Mice; published March 15, 20.12) http://theDowerfilm.OI-gldocuments/ComDrehcnsive list of 69 EMR studies with su m manes. pd f & http;/lelectromagnetichealth .. rglelectromagnetic-health ... o bloglrussia n- reDOf'tl and http://emf.mel·cola.com/siteslemf/emf:...dangel's.aspx lvww.bioinj tiative.org/report/index.
b tm

h ttp:lleol) 3clllfblog.net/wp-conten t/u pl08d5/26 lOllI/Reb IIttal-to~Klatls- Bend cr. IJdf-Li sts dozens of studi es at the end of the document.

The utilities and commissioners should take into consideration the fact that there will undoubtedly be massive numbers oflawsuits as the public becomes increasingly aware of, and affected by the health problems and fires associated with smart meters. The price tag involved in paying off the inestimable medical and suffering costs will, in a very short time, vastly override any profits resulting from the installation of smart meters. Already, insurance companies have hired iflciependent laboratory scientists and these scientists also observed cell damage and DNA chain breaks from exposure to RF radiation, and now the insurance companies will NOT insure liability damage from wireless smart meters and other wireless devices. See the following 3 minute TV video: hup:1I eOll3emtblog. net/? p=382 It is unimaginable what kind of liability will be faced from those unfortunate enough to sleep, live or work in a situation where they are opposite a bank of meters. According to my understanding and those of scientists with which I have spoken, this situation is a veritable death sentence. Respectfully submitted,


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