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July 6, 2016

Ronald M. Powell, Ph.D.

Comparison of the Radiofrequency/Microwave Radiation
Exposure: Wireless Smart Meter to Wireless ERT Meter
Introduction
The motivation for this document is the increasing concern about the biological effects caused by
exposure to even low levels of radiofrequency(RF)/microwave radiation from many wireless devices.
Those devices include new electric power meters that are equipped with RF/mcrowave transmitters and
receivers (“transceivers”).
This document compares the RF/microwave radiation from two Wireless Smart Meters that employ the
same RF/microwave transceiver, to a specific bubble-up Wireless ERT (Encoder Receiver Transmitter)
Meter, all of which are in use in Maryland and likely in many other states too. The particular Wireless
Smart Meters addressed here fall in a category of meters often called Automatic Metering Infrastructure
(AMI). The particular Wireless ERT Meter addressed here falls in a category of meters often called
Automatic Meter Reading (AMR). A comparison of the various types of electric power meters can be
found in the document “Ranking Electricity Meters for Risk to Health, Privacy, and Cyber Security”.1
The comparison provided here has a number of limitations, primarily for these reasons:

Some of the needed data could not be found.
An example is the number of transmissions per day, and the duration of each transmission, from
the 2.4 GHz transmitter in the Wireless Smart Meters. Lack of this data prevented including the
radiation from the 2.4 GHz transmitter in the comparison.
In some cases, assumptions had to be made to enable the comparison. Those assumptions are
called out where they are made. Hopefully, they are reasonable.

Some of the data found were inconsistent from source to source.
An example is the RF Power Output (EIRP)2 of the transmitter in the Wireless ERT Meter, which
varied from report to report by a factor over 100. As a result, decisions had to be made as to
which source was correct. Those decisions are noted where they were made. Measurements of
the characteristics of the Wireless ERT Meter, made by a colleague, helped in distinguishing data
that were correct, or applicable, from data that were not.

1

Ronald M. Powell, Ph.D., Ranking Electricity Meters for Risk to Health, Privacy, and Cyber Security, Document (5) on this
index: https://www.scribd.com/document/291507610.
2
EIRP stands for Effective (or Equivalent) Isotropic Radiated Power. It is the product of the RF Power Output of the device
and the gain of its antenna in the direction in which the EIRP is desired.

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There is no widely accepted basis for assigning a single value reflective of the biological impact of
the radiation exposure produced by digital RF/microwave transmissions, making comparison of
the radiation exposure from different wireless devices difficult.
This is an entirely understandable problem because so many characteristics of RF/microwave
radiation can conceivably play a role in the biological impact. In response, the comparison
offered here has been made on several bases, in order to provide as complete a picture as
possible.

The discussion presented here assumes some technical knowledge, so this paper may not be fully
accessible to general audiences. However, the results are stated in general terms in the Observations on
page 12. The abbreviations used in this document are shown in Table 1.

Table 1: Abbreviations
Power

Voltage

Length

Time

W
watt
mW
milliwatt
(one-thousandth of a watt)

V
volt
µV microvolt
(one-millionth of a volt)

m

s
second
ms millisecond
(one-thousandth of a second)

Power Density

Electric Field

Antenna
Gain

Frequency

mW/m2

V/m

volts per meter

dBi3 decibels,
isotropic

Hz

µV/m

microvolts per
meter

milliwatts per
square meter

meter

hertz (cycles per
second)
MHz megahertz (millions of
hertz)

Electric Field

Frequency

dBuV/m volts per
meter relative to 1
microvolt, in decibels4

GHz gigahertz (billions of
hertz)

Product Data
The data in Table 2, on pages 3, 4, and 5, describe the Wireless ERT Meter and the two Wireless Smart
Meters compared here. Because the two Wireless Smart Meters contain the same transceiver, they are
treated as identical here; and they are described in a single column in Table 2.
The data have been assembled from a host of sources shown in the footnotes. Any contradictions found
in the data, which are important to the comparisons made here, are resolved in the footnotes.
3

Antenna gain, in decibels, is measured relative to that of an isotropic antenna, which has a gain of 1. An isotropic antenna is
an ideal antenna that radiates equally in all directions. Such an antenna does not exist in reality but, nevertheless, provides a
useful, and thus widely used, basis for comparison. The value dBi is calculated as 10 log10(gA/gi) where gi = 1 is the gain of an
isotropic antenna and gA is the gain of the antenna whose dBi value is to be determined.
4
dBµV is calculated as 20 log10(E), where E is the electric field, expressed in microvolts, whose equivalent in dBµV is desired.

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Table 2: Data Describing the Wireless ERT Meter and the Wireless Smart Meters
(This table continues on pages 4 and 5.)
Characteristic
Meter
Family

main category
sub category

sub sub category
Reprogrammable

Wireless ERT Meter5
AMR (Automated Meter
Reading)7
ERT (Encoder Receiver
Transmitter)
bubble-up (one way)8
inconsistent reports9,10,11

Frequency
910-920 MHz spread
spectrum12,13
Frequency (continued)

5

Wireless Smart Meters6
AMI (Advanced Metering Infrastructure)
(not applicable)
(not applicable)
yes, wirelessly programmable
902-928 MHz (“900 MHz” for short)
frequency hopping spread spectrum
i210 Mesh radio14,12
2405.8-2480.9 MHz (“2.4 GHz” for short)
802.15.4 Zigbee Home Area Network
(HAN) radio14

General Electric/Itron I-210 ERT Meter with Itron FCC ID Number CDT52ESS transmitter/transceiver inside (sometimes
mislabeled CTD52ESS).
6
Many of the data in Table 2 are presented, in the following reference, as applicable to Wireless Smart Meters made by
General Electric and Landis+Gyr, both containing transceivers made by Silver Spring Networks, but no models are named.
The models are believed to be the GE I-210+c and the Landis+Gyr Focus AXR-SD Wireless Smart Meters, both containing the
Silver Spring Networks FCC ID Number OWS-NIC514 transceiver, and that assumption is made here. Pacific Gas and Electric
Company’s Response to Administrative Law Judge’s October 18, 2011 Ruling Directing it to File Clarifying Radio Frequency
Information. (http://emfsafetynetwork.org/wp-content/uploads/2011/11/PGERFDataOpt-outalternatives_11-1-11-3pm.pdf)
7
AMR is translated more than one way. Itron uses “Automated Meter Reading” and since a GE/Itron ERT meter is addressed
here, that translation is employed here (https://www.itron.com/na/solutions/Pages/Automated-Meter-Reading.aspx). Other
translations include “Automatic (Automated) Meter Reader (Reading).
8
A bubble-up ERT Meter is “one-way” in this sense: It has a transmitter but not a receiver. It transmits at fixed time
intervals, day and night, indefinitely, so that a signal is available whenever a handheld reader or a utility vehicle passes by. In
contrast a wake-up ERT Meter is “two-way” in this sense: It has a transmitter and a receiver (a “transceiver”) and transmits
only in response to a wake-up signal from a handheld reader or utility vehicle, which may pass by only once a month.
9
According to a communication from Itron, the manufacturer of the wireless module, many parameters of the 52ESS ERT
module are programmable both by the meter manufacturer and by the electric power company, including peak RF Power
Output, the antenna gain (which seems unlikely to me), transmission duration, and transmission rate.
10
According to a communication from General Electric, the manufacturer of the meter, the peak RF Power Output, the
transmission duration, and the transmission rate are set by Itron, the manufacturer of the 52ESS ERT module, and are not
adjustable.
11
In general terms, without reference to the 52ESS ERT module under discussion here, some AMR meters can accept
reprogramming signals, even if they normally operate in bubble-up mode: “There are also hybrid systems that combine oneway and two-way technologies, using one-way communication for reading and two-way communication for programming
functions.” Automatic Meter Reading, Wikipedia. (https://en.wikipedia.org/wiki/Automatic_meter_reading)
12
Spread spectrum transmissions are spread over multiple frequencies, within a specified frequency range, to achieve a
variety of technical and security aims.
13
Communication from CKC Certification Services, LLC, which is a testing laboratory used to prove compliance with FCC
requirements of the transmitters in wireless meters.
14
Silver Spring Networks, Emissions Test Report for a Low Power Transmitter, Report No. 09PRO009 (August 22, 2009),
page 1, obtained for FCC ID Number OWS-NIC514 from the FCC-ID web site. On the following web page, enter “OWS” under
“Grantee Code”, and enter “–NIC514” (inclusive of the leading hyphen) under Product Code. Then click on the first entry
“Detail” and then on “Test Report”, page 1. (http://transition.fcc.gov/oet/ea/fccid/)

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Characteristic
FCC Rule Governing Peak RF
Power Output
Antenna Gain
Peak RF
Power
Output

conducted from
transmitter
EIRP23 radiated
from antenna

Wireless ERT Meter5
FCC Part 15.24915,16,12
not found
not found
0.75 mW24,25,26

15

Wireless Smart Meters6
902-928 MHz: FCC Part 15.24717
2.400-2.4835 GHz: FCC Part 15.24718
900 MHz: 4.0 dBi19 (a factor of 2.5)
2.4 GHz: 0 dBi20,21 (a factor of 1)
900 MHz: 1 W22
2.4 GHz: 125 mW22
900 MHz: 2.5 W27
2.4 GHz: 125 mW28

Communication from the FCC.
See reference in footnote 17, page 19.
17
FCC Office of Engineering and Technology (OET), Federal Communications Commission: Understanding the FCC Regulations
for Low-Power, Non-Licensed Transmitters, Bulletin No. 63, October 1993, page 18.
(http://www.fcc.gov/Bureaus/Engineering_Technology/Documents/bulletins/oet63/oet63rev.pdf)
18
See reference in footnote 17, pages 20-21.
19
Pacific Gas and Electric Company’s Response to Administrative Law Judge’s October 18, 2011 Ruling Directing it to File
Clarifying Radio Frequency Information, page 10.
(http://emfsafetynetwork.org/wp-content/uploads/2011/11/PGERFDataOpt-outalternatives_11-1-11-3pm.pdf)
20
A gain of 0 dBi means no gain, which is equivalent to a factor of 1. Pacific Gas and Electric Company’s Response to
Administrative Law Judge’s October 18, 2011 Ruling Directing it to File Clarifying Radio Frequency Information, page 10.
(http://emfsafetynetwork.org/wp-content/uploads/2011/11/PGERFDataOpt-outalternatives_11-1-11-3pm.pdf)
21
Antenna gain is reported as 1 dBi (a factor of 1.26) at 2.4 GHz in Silver Spring Networks, Emissions Test Report for a Low
Power Transmitter, Report No. 09PRO009 (August 22, 2009), page 3 on FCC ID website, located as described in footnote 14.
But I have accepted the value of 0 dBi, referenced in footnote 20 as correct here, although the difference is small.
22
Pacific Gas and Electric Company’s Response to Administrative Law Judge’s October 18, 2011 Ruling Directing it to File
Clarifying Radio Frequency Information, page 10.
(http://emfsafetynetwork.org/wp-content/uploads/2011/11/PGERFDataOpt-outalternatives_11-1-11-3pm.pdf)
23
EIRP is the Effective (or Equivalent) Isotropic Radiated Power. It is the product of the conducted RF Power Output from the
transmitter and the antenna gain as a regular number, or factor, not in decibels.
24
Communication from General Electric. Type of RF Power Output in that communication is assumed to be EIRP, not the
conducted RF Power Output from the transmitter, because 0.75 mW is the maximum EIRP value permitted by FCC Part
15.249 as shown in reference in footnote 17, page 18, although expressed there as a peak electric field of 50,000 µV/m at 3
meters.
25
Communication from the Federal Communications Commission, specifically identifying this value as EIRP.
26
Reported as 75 mW for the 52ESS ERT Module in STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE
COMMISSION In the matter of the Commission’s motion requiring INDIANA MICHIGAN POWER COMPANY to submit
information for the review of issues bearing on the deployment of smart meters by regulated utilities in Michigan, Comments
of Indiana Michigan Power Company, Case No. U-17000, March 16, 2012, page 8. I dismissed this value of 75 mW as
incorrect for the ERT Meter under consideration here and accepted the 0.75 mW value as correct.
(http://efile.mpsc.state.mi.us/efile/docs/17000/0147.pdf)
27
The EIRP is the conducted RF Power Output from the transmitter times the gain of the antenna, thus 1 W times 2.5, or
2.5 W.
28
The EIRP is the conducted RF Power Output from the transmitter times the gain of the antenna, thus 125 mW times 1, or
125 mW.
16

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Characteristic
Peak RF
µV/m
Electric Field dBµV/m

Transmission Rate

Wireless ERT Meter5
50,000 µV/m at 3 meters29
94 dBµV/m at 3 meters31
Reported:
43,200 transmissions per
day32,33
Measured:
68,640 transmissions per day

Transmission Duration

6 ms32,35

Ratio of Time-Average RF
Power to Peak RF Power in
each Transmission

not found, assume 0.5

Wireless Smart Meters6
not found (but calculable)30
not found (but calculable)30
900 MHz:
Average Rate: 9,981 per day34
Maximum Rate: 190,396 per day
(99th percentile)34
2.4 GHz: not found
900 MHz:
At Average Rate: 6.2 ms36
At Maximum Rate: 4.6 ms37
2.4 GHz: not found
900 MHz: not found, assume 0.5
2.4 GHz: not found

Please note that no data could be found for the “Ratio of the Time-Average RF Power to the Peak RF
Power” in each transmission for either meter. That Ratio must fall in the following range:
0 < ????? ≤ 1
So an intermediate value of 0.5 has been assumed here for both types of meters, which effectively
removes this characteristic from the comparison. Clearly, if one or the other of these two assumed

29

Maximum permitted by FCC Part 15.249 Rule, Office of Engineering and Technology, Federal Communications Commission,
Understanding the FCC Regulations for Low-Power, Non-Licensed Transmitters, OET Bulletin No. 63 (October 1993), page 18.
30
While the data were not found, they are calculable from other data that were found.
(https://transition.fcc.gov/Bureaus/Engineering_Technology/Documents/bulletins/oet63/oet63rev.pdf)
31
Communication from the Federal Communications Commission. This value for the electric field of 50,000 µV/m at 3 meters
is equivalent to an electric field of 94dBµV/m at 3 meters, and both of them are equivalent to an EIRP of 0.75 mW.
32
1 SCM (Standard Consumption Message) every 2 seconds. Communication from General Electric.
33
Reported as 1 transmission every second in reference in footnote 26, or twice the rate reported in a communication from
General Electric; but the General Electric value is accepted as the more likely to be correct, given the other discrepancies in
the reference in footnote 26.
34
Pacific Gas and Electric Company’s Response to Administrative Law Judge’s October 18, 2011 Ruling Directing it to File
Clarifying Radio Frequency Information, page 5.
(http://emfsafetynetwork.org/wp-content/uploads/2011/11/PGERFDataOpt-outalternatives_11-1-11-3pm.pdf)
35
Reported as 0.00586 seconds in reference in footnote 26, consistent with a communication from General Electric.
36
See Table 2-1 and footnote 4 on page 5 in the following reference. 9,981 transmissions within an average (“mean”)
duration of 62 seconds which indicates 62/9,981 or 0.0062 seconds average duration per transmission. Pacific Gas and
Electric Company’s Response to Administrative Law Judge’s October 18, 2011 Ruling Directing it to File Clarifying Radio
Frequency Information.
(http://emfsafetynetwork.org/wp-content/uploads/2011/11/PGERFDataOpt-outalternatives_11-1-11-3pm.pdf)
37
See Table 2-1 on page 5 in reference in footnote 36. 196,396 transmissions in 875.0 seconds indicates 875/196,396 or
0.0046 seconds average duration per transmission. However, the 875.0 seconds does not carry a footnote to tell us if this is
truly an average value. Rather, the row heading in the left column describes the 875.0 seconds as the “weighted average
duty cycle” without defining the weighting. But the 875.0 seconds is used here because it is the only value provided.
However, the true average (“mean”) value may be higher, as was the case for the “weighted average duty cycle” of 45.3
seconds in the middle column of Table 2-1, which was footnoted to indicate that the average (“mean”) value was 62 seconds.

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values is far from correct, then the comparisons of Time-Average RF Power and Time-Average RF Power
Density made in this document will not be correct.

Bases for Comparison of the Radiation Levels
There are many different characteristics of RF/microwave radiation that are potentially relevant to the
biological effects caused by that radiation. Some of those characteristics are interdependent. Examples
follow:
Peak RF Power Density
Transmission Rate
Transmission Duration
Ratio of Time-Average RF Power Density to Peak RF Power Density in a transmission
Time-Average RF Power Density (dependent on all four of the above)
Frequency
Modulation Method (affects several of the above)
The international biomedical research community is gradually sorting out the relationships between the
characteristics of RF/microwave radiation and the biological effects. This is immensely complicated
work that will undoubtedly continue for many years to come. Different biological effects can have very
different dependencies on these several characteristics, so the proper characterization of the biological
risk associated with radiation exposure will always be complex.
In this document I have compared those characteristics of the radiation from the Wireless Smart Meters
and from the Wireless ERT Meter for which I could find relevant data. Table 3 and Table 4, which follow,
show those comparisons on the first four bases above. The Peak RF Power Output (EIRP) is important to
Peak RF Power Density, because the meter with the greater Peak RF Power Output will produce the
higher value of the Peak RF Power Density at a given distance, other characteristics being the same.
Similarly, the RF Energy Output per Day is important to the Time-Average RF Power Density because the
meter with the greater RF Energy Output per Day will produce the greater Time-Average RF Power
Density at a given distance, other characteristics being the same.

Comparison of Smart Meter to the ERT Meter with the “Reported”
Transmission Rate
Table 3 uses the data from Table 2 to compare the radiation exposure of the Wireless Smart Meters to
the radiation exposure of the Wireless ERT Meter at 900 MHz, using the “reported” transmission rate of
43,200 per day for the ERT Meter. The basis for the comparison is shown on the left side of the table.
The calculation for the comparison appears in the center of the table. And the calculated value of the
comparison appears on the right side of the table in bold.

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Table 3: Radiation Comparison of Wireless Smart Meter (SM) to Wireless ERT Meter at
900 MHz Using “Reported” Transmission Rate of 43,200 per Day for ERT Meter
Basis for Comparison
1

Peak RF Power Output (EIRP)
Transmission Rate
2
Average Rate for SM38
Maximum Rate for SM
Transmission Duration
At Average Rate for SM
3
At Maximum Rate for SM
Ratio of Time-Average to Peak
4
RF Power in Each Transmission
RF Energy Output per Day
(product of 1, 2, 3, and 4)
1x2x3x4
At Average Rate for SM
At Maximum Rate for SM

2.5 W / 0.75 mW =

Comparison
Smart Meters to ERT
Meter
3,300

9,981 per day/ 43,200 per day =
190,396 per day / 43,200 per day =

0.23
4.4

6.2 ms / 6 ms =
4.6 ms / 6 ms =

1.03
0.77

0.5/0.5 =

1

3,300 x 0.23 x 1.03 x 1 =
3,300 x 4.4 x 0.77 x 1 =

78039
11,000 39

Calculation of Comparison
(Smart Meters / ERT Meter)

The above comparisons show that the Smart Meters, compared to the ERT Meter,



transmit a Peak RF Power Output (EIRP) that is 3,300 times greater
have a transmission rate that is 0.23 times smaller on average, and 4.4 times greater at a
maximum
have a transmission duration that ranges from virtually the same (1.03) to somewhat shorter
(0.77)
produce a RF Energy Output per Day that is 780 times greater on average, and 11,000 times
greater at a maximum.
Multiplying bases 1, 2, 3, and 4 together enables computing a plausible ratio of the RF Energy
Output per Day produced by the two types of meters.
Caveat: However, as shown in the last row of Table 2, I could find no data to support basis 4
in Table 3. So I have assumed a ratio of 0.5 for both types of meters, effectively removing
basis 4 from the comparison in the last row of Table 3.

Comparison of Smart Meter to the ERT Meter with the “Measured”
Transmission Rate
Table 4 uses the data from Table 2 to compare the radiation exposure of the Wireless Smart Meter to
the Wireless ERT Meter at 900 MHz, again, but this time using the somewhat higher “measured”
38
39

SM means Smart Meter.
To two significant figures.

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transmission rate of 68,640 transmissions per day for the ERT Meter.40 The purpose is to show the
effect of the higher “measured” value. Again, the basis for the comparison is shown on the left. The
calculation for the comparison appears in the center. And the calculated value of the comparison
appears on the right side of the table in bold.

Table 4: Radiation Comparison of Wireless Smart Meter (SM) to Wireless ERT Meter at
900 MHz Using “Measured” Transmission Rate of 68,400 per day for ERT Meter
Basis for Comparison
1

Peak RF Power Output (EIRP)
Transmission Rate
2
Average Rate for SM
Maximum Rate for SM
Transmission Duration
3
At Average Rate for SM
At Maximum Rate for SM
Ratio of Time-Average to Peak
4
RF Power in Each Transmission
RF Energy Output per Day
(product of 1, 2, 3, and 4)
1x2x3x4
At Average Rate for SM
At Maximum Rate for SM

2.5 W / 0.75 mW =

Comparison
Smart Meters to
ERT
3,300

9,981 per day/ 68,640 per day =
190,396 per day / 68,640 per day =

0.15
2.8

6.2 ms / 6 ms =
4.6 ms / 6 ms =

1.03
0.77

0.5/0.5 =

1

3,300 x 0.15 x 1.03 x 1 =
3,300 x 2.8 x 0.77 x 1 =

51041
7,10041

Calculation of Comparison
(Smart Meters / ERT Meter)

The above comparisons show that the Smart Meters, compared to the ERT Meter,



transmit a Peak RF Power Output (EIRP) that is 3,300 times greater
have a transmission rate that is 0.15 times smaller on average, and 2.8 times greater at a
maximum
have a transmission duration that ranges from virtually the same (1.03) to somewhat shorter
(0.77)
produce a RF Energy Output per Day that is 510 times greater on average, and 7,100 times
greater at a maximum.
Again, multiplying the bases 1, 2, 3, and 4 together enables computing a plausible ratio for
the RF Energy Output per Day produced by the two types of meters.
Caveat: However, as shown in the last row of Table 2, I could find no data to support
comparison 4 in Table 4. So I have assumed a ratio of 0.5 for both types of meters. ,
effectively removing basis 4 from the comparison in the last row of Table 4.

40

The “measured” value of 68,400 transmissions per day was determined by actual measurement, by a colleague, of the
specific ERT Meter being addressed here.
41
To two significant figures.

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Comparisons Based on the Precautionary Action Level in the BioInitiative
2012 Report
Table 5 compares the Peak RF Power Density to the BioInitiative Precautionary Action Level. Table 6
compares the Time-Average RF Power Density to the BioInitiative Precautionary Action Level. Such
comparisons can be made because the BioInitiative Precautionary Action Level is itself expressed as an
RF Power Density. Specifically, it is described as the “precautionary action level for chronic exposure to
pulsed RFR” (radiofrequency radiation) in the BioInitiative 2012 report.42
Note that the Peak and Time-Average levels the RF Power Density can differ greatly for pulsed digital
signals. Pulsed digital signals can have very high values of Peak RF Power Density, while having much
lower values of Time-Average RF Power Density. The reason for the difference is that the duration of a
given transmission from a digital device can be very short compared to the time between transmissions,
as is true for both the Wireless Smart Meters and the Wireless ERT Meter examined here.

Comparing the Peak RF Power Density of the Meters to the BioInitiative
Precautionary Action Level
Table 5 compares the Peak RF Power Density, at distances of 1 meter and 3 meters from both the Smart
Meters and the ERT Meter, to the Precautionary Action Level, 0.006 mW/m2, in the BioInitiative 2012
Report. Table 5 draws all of its data from Table 2. The columns called “Calculation” show how a given
“Value” or a given “Comparison” was calculated. The ultimate comparisons are shown in the right
column of the table in bold.

Table 5: Peak RF Power Density from a Wireless Smart Meter and a Wireless ERT Meter
Compared to Precautionary Action Level in the BioInitiative 2012 Report
Distance
(meters)
?

Smart
Meters
ERT
Meter

1
3
1
3

Peak RF Power Density
Calculation
????
????

2500 mW/ (4π12) =
2500 mW/ (4π32) =
0.75 mW / (4π12) =
0.75 mW / (4π32) =

Value
(mW/m2)
20043
2243
0.06043
0.006643

42

BioInitiative
Precautionary
Action Level
(mW/m2)42

Compare Peak RF Power
Density to BioInitiative Action
Level
Calculation
Comparison
???? ?? ?????
?????? ?????

0.006
0.006
0.006
0.006

200 / 0.006 =
22 / 0.006 =
0.060 / 0.006 =
0.0066 / 0.006 =

33,000
3,700
10
1.1

“Precautionary action level for chronic exposure to pulsed RFR” is described here: BioInitiative Working Group, Cindy Sage
and David O. Carpenter, Editors, BioInitiative Report: A Rationale for Biologically-based Public Exposure Standards for
Electromagnetic Radiation, Section 1, Summary for the Public (2014 Supplement) by Cindy Sage, March 2014, sequential
page 18. The Precautionary Action Level is described as 3 to 6 microwatts per square meter. I used the higher of the two
levels here. (http://www.bioinitiative.org/report/wp-content/uploads/pdfs/sec01_2012_summary_for_public.pdf)
43
To two significant figures.

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The above comparisons support the following observations:

Both types of meters produce Peak RF Power Density levels that exceed the Precautionary Action
Level in the BioInitiative 2012 Report at distances of both 1 meter and 3 meters.
The Wireless Smart Meter exceeds the BioInitiative Precautionary Action Level by thousands, to
tens of thousands, of times.
The Wireless ERT Meter exceeds the BioInitiative Precautionary Action Level by 10 times at a
distance of 1 meter, but virtually matches the Precautionary Action Level at 3 meters.


Comparing the Time-Average RF Power Density of the Meters to the
BioInitiative Precautionary Action Level
Table 6 compares the Time-Average RF Power Density of the Wireless Smart Meters and the Wireless
ERT Meter to the Precautionary Action Level, 0.006 mW/m2, in the BioInitiative 2012 Report.42 Table 6
draws its data from Table 2 or from the calculations in Table 5. Once again, the columns called
“Calculation” show how a given “Value” or a given “Comparison” was calculated. The ultimate
comparisons are shown in bold in the right column of the table.

Table 6: Time-Average RF Power Density from a Wireless Smart Meter and a Wireless
ERT Meter Compared to Precautionary Action Level in the BioInitiative 2012 Report
Meter
Type

Distance
(meters)

Peak RF
Power
Density
2

(mW/m )
?

1

????
????

200

Transmission Parameters
Ratio of
TimeAverage to
Peak RF
Power in
Each
Transmission

0.5

44

Smart
Meter
3

1

43

22

0.060

0.5

0.5

44

44

ERT
Meter
3

44

0.0066

0.5

44

Time-Average RF Power Density

Compare Time-Average RF
Power Density to
Precautionary Action Level

Rate
(per day)

Duration
(ms)

Calculation

Value
2
(mW/m )

Calculation

Comparison

Average:
9,981

6.2

9,981
6.2
200(0.5) (
)(
)=
24 ∗ 60 ∗ 60 1000

0.072

0.072
=
0.006

12

Maximum:
190,396

4.6

190,396
4.6
200(0.5) (
)(
)=
24 ∗ 60 ∗ 60 1000

1.0

1.0
=
0.006

170

Average:
9,981

6.2

9,981
6.2
22(0.5) (
)(
)=
24 ∗ 60 ∗ 60 1000

0.0079

0.0079
=
0.006

1.3

Maximum:
190,396

4.6

190,396
4.6
200(0.5) (
)(
)=
24 ∗ 60 ∗ 60 1000

0.11

0.11
=
0.006

19

Reported:
43,200

6

43,200
6
0.060(0.5) (
)(
)=
24 ∗ 60 ∗ 60 1000

0.000089

0.000089
=
0.006

0.015

Measured:
68,400

6

68,400
6
0.060(0.5) (
)(
)=
24 ∗ 60 ∗ 60 1000

0.000014

0.000014
=
0.006

0.024

Reported:
43,200

6

43,200
6
0.0066(0.5) (
)(
)=
24 ∗ 60 ∗ 60 1000

0.0000099

0.0000099
=
0.006

0.0017

Measured:
68,400

6

68,400
6
0.0066(0.5) (
)(
)=
24 ∗ 60 ∗ 60 1000

0.000016

0.000016
=
0.006

0.0026

Assumed values, as explained in Table 2.

Page 10 of 15

The above comparisons support the following observations:

The Time-Average RF Power Density of the Wireless Smart Meters exceeds the Precautionary
Action Level at distances of both 1 meter and 3 meters.

The Time-Average RF Power Density of the Wireless ERT Meter is less than the Precautionary
Action Level at distances of both 1 meter and 3 meters.

What about the 2.4 GHz transmitter in the Wireless Smart Meter?
In Table 3, Table 4, Table 5, and Table 6, the radiation exposure produced by the 2.4 GHz transmitter in
the Wireless Smart Meters is not addressed. The reason is that I could not find sufficient data. The RF
Power Output, of 125 mW (EIRP), was located; and that level is 20 times less than the RF Power Output
of 2.5 W (EIRP) at 900 MHz. But I could find no information on either the transmission rate or the
transmission duration for the 2.4 GHz transmitter. In principal, that rate and that duration could easily
be high enough to make the 2.4 GHz transmitter the dominant source of radiation from the Wireless
Smart Meter, on the basis of Energy Output per Day. But whatever the data are, the inclusion of the
radiation from the 2.4 GHz transmitter can only raise the total radiation exposure produced by the
Wireless Smart Meters, making them compare even less favorably with the Wireless ERT Meter.

What about other Wireless ERT Meters?
The analysis presented here is valid only for the specific make and model of the Wireless ERT Meter
named in this document. Other Wireless ERT Meters can be very different. Specifically, I have observed
that at least one other Wireless ERT Meter currently offered can produce much higher Peak RF Power
Outputs up to 100 mW (presumably EIRP), 45 which is 133 times the Peak RF Power Output of the ERT
Meter discussed above (0.75 mW EIRP). To see the effects of this increased power level, see Appendix 1,
beginning on page 14.
Since the high-power Wireless ERT Meter is apparently intended for basement or below-grade locations,
electric power companies may prefer such meters for installations inside homes because indoor
locations are often in basements.
Economic factors favor the adoption of high-power models for at least two reasons:

High-power Wireless ERT meters can be read from greater distances, requiring fewer miles to be
traveled for handheld or mobile readers.

45

Itron Centron C1SR R300 IDM High Power personality module has an RF Power Output up to 20 dBm (100 mW, presumably
EIRP). “The higher-powered R300 is designed for particularly hard-to-read installations such as basements and below-grade
locations, as well as gated communities, airports, and military installations. An additional benefit of the higher-powered R300
is a lower infrastructure cost; greater transmission distance equates to fewer repeaters and collectors.” “In addition, the
R300 IDM High Power is also capable of delivering interval data messages (IDM) to the Itron fixed Network AMR system to
calculate ANSI standard demand, time-of-use (TOU), and load profiling information.”
(http://www.itron.com/na/PublishedContent/100712SP-03%20CENTRON%20C1SR%20R300%20Meter.pdf)

Page 11 of 15

High-power Wireless ERT Meters provide the option of employing a fixed network collection
technology, as Wireless Smart Meters do, eliminating handheld and mobile readers entirely, and
enabling the collection of even more data (possibly increasing privacy concerns).

Observations
Several important observations can be made, based on the above discussion:

Data from a document ordered by a California court, and from a document ordered by the
Michigan Public Service Commission, were employed in this comparison. Without such data,
even the limited comparison presented here would not have been possible. But even with such
data, there were enough conflicts among the reported data from various sources that
measurements were needed to resolve those conflicts with a reasonable degree of confidence.
Further, some data essential to a proper comparison could not be found at all, including:
o the number of transmissions per day, and the duration of those transmissions, for the
2.4 GHz transmitter in the Wireless Smart Meters
o the ratio of RF Peak Power Output to Time-Average Power Output for the individual
transmissions at 900 MHz for both the Wireless Smart Meters and the Wireless ERT
Meter, making an assumption necessary to support the calculations.
So, we may fairly ask:
Can the general public expect to learn, from readily available published data, enough
information to determine the radiation exposure from a wireless electric meter?
It appears, based on my experience in preparing this document, that the answer is “No.”

While the specific Wireless ERT Meter addressed in this comparison presented a much lower
radiation exposure than the Wireless Smart Meters, the exposure of the Wireless ERT Meter may
not be negligible, based primarily on the Peak RF Power Density produced. Further, the levels of
RF/microwave radiation that are harmful are still being explored by the international biomedical
research community. So, the discovery of biological effects at progressively lower levels is still a
possibility. For this reason, committing to exposure, 24 hours a day for a lifetime, to the lower
level of radiation exposure presented by the Wireless ERT Meter addressed here may not be
prudent.

As shown above, there are other Wireless ERT Meters with RF Power Outputs that are 100 times
greater, or more, than the specific Wireless ERT Meter addressed here. And there are strong
economic motivations for the use of such high-power Wireless ERT Meters. So the mere fact that
a meter is called an “Wireless ERT Meter”, with no further information about that meter, is
insufficient to indicate, even within a factor of 100 or so, what its radiation exposure might be.

Page 12 of 15

 What about wake-up Wireless ERT Meters? 46 They transmit only in response to a wake-up signal
from a passing handheld reader or utility vehicle, which occurs perhaps once a month. So, it
seems very likely that such meters will produce considerably less radiation exposure than the
bubble-up Wireless ERT Meter addressed here. But whether such limited bursts of radiation will
still prove disruptive to some individuals is not clear at this time. Further, I have yet to encounter
a single installation of a wake-up Wireless ERT Meter for electricity.

Wireless Smart Meters, or Wireless ERT Meters, are not generally installed in isolation, but rather
are installed throughout a community. So, wherever one of these is installed, there are likely
many others. Further, a given community may also have wireless water meters, wireless natural
gas meters, nearby cell towers, and nearby broadcast services, among other sources of radiation.
The human body “receives” them all. The implication is that any limit placed on the radiation
exposure from a single source may not be adequate to protect a community from the sum total
of the radiation produced by all sources present.

46

A bubble-up ERT Meter is “one-way” in this sense: It has a transmitter but not a receiver. It transmits at fixed time
intervals, day and night, indefinitely, so that a signal is available whenever a handheld reader or a utility vehicle passes by. In
contrast, a wake-up ERT Meter is “two-way” in this sense: It has a transmitter and a receiver (a “transceiver”) and transmits
only in response to a wake-up signal from a handheld reader or utility vehicle, which may pass by only once a month.

Page 13 of 15

APPENDIX 1
Consider a high-power bubble-up Wireless ERT Meter with a Peak RF Output Power of 100 mW. Such a
meter does exist, as noted above; but I lack data on its other characteristics. If its other characteristics
were the same as those of the specific Wireless ERT Meter addressed above, then this hypothetical
high-power Wireless ERT Meter would lead to the comparisons shown in Table 7 and Table 8 below.

Table 7: Peak RF Power Density from a Hypothetical High-Power Wireless ERT Meter
Compared to Precautionary Action Level in the BioInitiative 2012 Report
Distance
(meters)

Calculation

?

ERT
Meter

Peak RF Power Density
Value
(mW/m2)

????
????

100 mW/ (4π12) =
100 mW / (4π32) =

1
3

BioInitiative
Precautionary
Action Level
(mW/m2)42

Compare Peak RF Power
Density to BioInitiative Action
Level
Calculation
Comparison
???? ?? ?????
?????? ?????

8.0
0.88

0.006
0.006

8.0 / 0.006 =
0.88 / 0.006 =

1300
150

The above comparisons support the following observations about the hypothetical high-power Wireless
ERT Meter:

The Peak RF Power Density of the hypothetical high-power ERT Meter would exceed the
Precautionary Action Level in the BioInitiative 2012 Report by a factor of 1300 at a distance of
1 meter, and by a factor of 150 at a distance of 3 meters.

Table 8: Time-Average RF Power Density from a Hypothetical High-Power Wireless ERT
Meter Compared to Precautionary Action Level in the BioInitiative 2012 Report
Meter
Type

Distance
(meters)

Peak RF
Power
Density
2

(mW/m )
?

1

????
????

8.0

Transmission Parameters
Ratio of
TimeAverage to
Peak RF
Power in
Each
Transmission

0.5

44

ERT
Meter
3

0.88

0.5

44

Time-Average RF Power Density

Compare Time-Average RF
Power Density to
Precautionary Action Level

Rate
(per day)

Duration
(ms)

Calculation

Value
2
(mW/m )

Calculation

Comparison

Reported:
43,200

6

43,200
6
8.0(0.5) (
)(
)=
24 ∗ 60 ∗ 60 1000

0.012

0.012
=
0.006

2.0

Measured:
68,400

6

68,400
6
8.0(0.5) (
)(
)=
24 ∗ 60 ∗ 60 1000

0.019

0.019
=
0.006

3.1

Reported:
43,200

6

43,200
6
0.88(0.5) (
)(
)=
24 ∗ 60 ∗ 60 1000

0.0013

0.0013
=
0.006

0.22

Measured:
68,400

6

68,400
6
0.88(0.5) (
)(
)=
24 ∗ 60 ∗ 60 1000

0.0021

0.0021
=
0.006

0.35

Page 14 of 15

The above comparisons support the following observations about the hypothetical high-power Wireless
ERT Meter:

The Time-Average RF Power Density of the hypothetical high-power Wireless ERT Meter would
exceed the Precautionary Action Level by a factor of 2 or 3 at a distance of 1 meter, and would
fall below that Action Level at a distance of 3 meters.

Page 15 of 15