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In the Matter of the Application of San Diego Gas & Electric Company (U 902 E) for Adoption of its Smart Grid Deployment Plan And Related Matters.

A.11-06-006 (Filed June 6, 2011) A. 11-06-029 A. 11-07-001

CENTER FOR ELECTROSMOG PREVENTIONS REPLY COMMENTS ON THE CPUC STAFF REPORT ON WORKSHOPS FOR SMART GRID DEPLOYMENT The Center for Electrosmog Prevention (CEP) submits the following reply comments on the report issued by the California Public Utilities Commission (CPUC) staff on March 1, 2012. Pursuant to the assigned Administrative Law Judge (ALJ) ruling dated November 22, 2011, and subsequent e-mails from the CPUC staff, these comments are timely. CEP agrees with the Greenlining Institute, in that the Commission should not approve the utilities' Smart Grid Deployment Plans (Plans): "The Commission should not approve the utilities Smart Grid Deployment Plans (Deployment Plans or Plans) unless and until they are amended to remedy the significant deficiencies identified in both the Staff Report and the comments of several parties throughout this proceeding. The plans as written are not compliant with SB 17.... and should not be approved until they are." (COMMENTS OF THE GREENLINING INSTITUTE ON THE SMART GRID WORKSHOP REPORT, p.1, CEP refers to our previous comments concerning SB 17, codified and chaptered into California Public Utilities (PU) Code 8360-69, [which] states, It is the policy of the state to modernize the state's electrical transmission and distribution system to maintain safe, reliable, efficient, and secure electrical service (CENTER FOR ELECTROSMOG
CEP Reply Comments on Staff Smart Grid Workshop Report

PREVENTIONS COMMENTS ON THE CPUC STAFF REPORT ON WORKSHOPS FOR SMART GRID DEPLOYMENT, p. 1, CEP agrees with Greenlining that there are multiple x-factors (unknowns) (Greenlining Comments, p. 4-5) that have arisen already, due to a very rapidly emerging set of technologies, and which have weakened and can weaken the electrical grid, due to hasty and inadequate planning. Numerous x-factors not mentioned by Greenlining or many of the commenters are those related to safety (the increased, involuntary, pervasive exposure to rf radiation of customers and the general public; the impact of a mesh network on biological beings; and those related to risking the reliability, efficiency, and security of the electrical grid and electrical service, aforementioned in CEP's previous comments.(CENTER FOR ELECTROSMOG PREVENTIONS COMMENTS ON THE CPUC STAFF REPORT ON WORKSHOPS FOR SMART GRID DEPLOYMENT, p. 1-15, In addition to the very troubling increased exposure to rf radiation and its impact on all biological beings, is the emerging smart grid's fragility, w/ massive x-factors and known factors not taken into proper consideration that will impact all these vital areas mandated by SB 17: safety, reliability, efficiency, and security. In addition to causing unprecedented amounts of electromagnetic pollution (EMP), the "smart" grid is exceedingly vulnerable to solar or manmade electromagnetic attacks such as (nuclear) High Altitude ElectroMagnetic Pulse (HEMP) and Non-Nuclear EMP (NNEMP), Intentional ElectroMagnetic Interference (IEMI) and cyber attacks. "Vulnerability to Space Weather, Manmade EMP & Cyber Attack" a recent publication by Isaac Jamieson, PhD, delineates these weaknesses, in great detail. The publication is located on the Radiation Research Trust (UK) website as Addendum to SMART METERS SMARTER PRACTICES, was presented to the UK Department of Energy and Climate Change in Whitehall on March 20, 2012. The report is attached herein, in its entirety, as a must-read to illustrate serious factors that have not been considered or mentioned by the CPUC, utilities, or other commentators, that can destroy our electric grid for a long time, possibly permanently, placing our state and nation at grave risk.

CEP Reply Comments on Staff Smart Grid Workshop Report

Copies of the main report, SMART METERS SMARTER PRACTICES, were delivered to 10 Downing Street by UK Radiation Research Trust representatives and two Members of Parliament last year. Questions related to its findings have since been asked in the UK Parliament. The document was also presented at a meeting on EMF and Health in the European Parliament in 2011. During the talk Dr. Jamieson gave at that time, he emphasized the importance of "best practices" in regards to smart energy meters and that a wireless system for energy meters is not only very fragile (to solar flares for instance) but also that the microwave radiation emitted by the smart meters poses a direct threat to public health. As noted by Dr Gerd Oberfeld at the same meeting, "The precautionary principle should be applied." The smart grid is being developed too hastily and without a coherent and detailed plan, ignoring risks and harms that have already emerged and are likely to emerge in a variety of ways. Our national and personal security depends on safety, reliability, efficiency, and security of the electrical grid. Therefore, the Plans should be rejected, the smart grid program should be halted, reevaluated for weaknesses including all of the above and any other criticisms, by all stakeholders, and reconstructed in a responsible manner.

March 21, 2012

Respectfully submitted,

/S/ Martin Homec P. O. Box 4471 Davis, CA 95617 (530) 867-1850 (530) 686-3968

CEP Reply Comments on Staff Smart Grid Workshop Report