Cases 9207 and 9208 April 5, 2012 David J.

Collins Executive Secretary Maryland Public Service Commission William Donald Schaefer Tower 6 St. Paul Street, 16th Floor Baltimore, MD 21202 Re: Maryland Public Service Commission Request for Comments Case No. 9207– Potomac Electric Power Company and Delmarva Power and Light Company Request For Deployment of Advanced Meter Infrastructure Case No. 9208 - Baltimore Gas and Electric Company - In the Matter of the Authorization to Deploy a Smart Grid Initiative and to Establish a Surcharge Mechanism for the Recovery of Costs Dear Mr. Collins:

Thank you for the opportunity to provide written comments on whether the Maryland Public Service Commission should require the subject utilities to offer customers the opportunity to opt out of receiving a smart meter (Case 9207 and Case 9208). The Center for Safer Wireless is a 501 (c)(3) national nonprofit organization that improves public understanding of wireless products and technology It’s interesting that this hearing is scheduled since Section 1252 Smart Metering of the US Energy Policy Act of 2005 states “Each electric utility subject to subparagraph (A) shall provide each customer requesting a time-based rate (bolding added) with a time-based meter capable of enabling the utility and customer to offer and receive such rate, respectively”. Have Pepco customer’s requested smart meters? On the frequently asked questions section of the Pepco website, question 3.7 is “Can I keep my current meter? Pepco’s answer is “No. Pepco is authorized by the Maryland Public Service Commission to remove its current meters and install our smart meters for all of its Maryland customers.” I wonder if this is a true statement since I found no statement in Maryland Public Service Commission orders involving Cases 9207 and 9208 that smart meters are mandatory in Maryland. The Center for Safer Wireless supports a program to allow customers to retain their analog meters in Maryland because smart meters pose the following concerns: 1. Privacy and security risks 2. Health risks
Center for Safer Wireless * P.O. Box 166 * Haymarket, Virginia 20168 *U.S.A.* 703-431-1558 www.centerforsaferwireless.org

Cases 9207 and 9208 Maryland Public Service Commission Comments

3. Interference and fire risks 4. Questionable energy savings
Introduction

The installation of smart meters on homes will create a wireless mesh of microwave radiation as home area networks are added in dwellings. After residents purchase new appliances with smart chips, their exposure to microwave radiation in the home will substantially increase. The smart chips will record what time the appliance was used, how long it was used, and what time the use ended. It will wirelessly send the data to the home’s smart meter. Visualize a spider-web of microwave transmissions as data moves throughout the home from televisions sets, stereos, home entertainment systems, telephones, computers, printers, dishwashers, washer and dryers, dishwashers, refrigerators, microwave ovens, toasters, hair dryers, electric tooth brushes etc to the smart meter. In addition, there is another layer of microwave transmissions to residents as one smart meter communicates with the next door neighbors’ smart meter and the next smart meter. The wireless communication continues until the data reaches a collector meter, wherein the data is transmitted to the utility via a cell tower. As reported by the San Diego Gas and Electric Company (SDGE) in response to a request from an Administrative Judge, smart meters installed by SDGE transmit messages on average 1270 times per day and at a maximum 25,920 times each day.1 Pacific Gas and Electric reported that up to 190,000 messages can be communicated via one smart meter in only 24 hours. 2
Privacy Concerns

Smart meters raise privacy concerns. According to a February 2012 Congressional Research Service Report entitled Smart Meter: Privacy and Cybersecurity, the Department of Energy reported that by matching data with known appliance load signatures, smart meters will be able to reveal people’s daily schedules, their appliances and electronic equipment, and whether they use certain types of medical equipment. 3 Utilities will have the data to discern the behavior of occupants in their home over a period of time. This mandatory device on our homes will track more private information than a GPS affixed to a criminal’s car, even though the US Supreme Court Case recently determined that a warrant was needed in the GPS case.

1 Trial, Allen, Attorney San Diego Gas and Electric Company, Response of San Diego Gas and Electric Company on the Administrative Law Judge’s
Ruling Seeking Clarification Before the Public Utilities Commission, November 1, 2011, pg. 6.

2.

Ann and Chonda J. Nwamu, Pacific Gas and Electric Law Department, PACIFIC GAS AND ELECTRIC COMPANY’S RESPONSE TO ADMINISTRATIVE LAW JUDGE’S OCTOBER 18, 2011 RULING, DIRECTING IT TO FILE CLARIFYING RADIO FREQUENCY INFORMATION, November 1, 2011, page 5. 3 Murrill, Brandon J., Liu, Edward C., and Thompson, Richard M., Smart Meter Data: Privacy and Cybersecurity, Congressional Research Service, February 3, 2012. Page 4.

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Cases 9207 and 9208 Maryland Public Service Commission Comments

The Electronic Privacy Information Center cites a list of potential privacy consequences of Smart Grid Systems including, identity theft, activity censorship, profiling, tracking behavior of renters/leasers, and real-time surveillance. In a recent radio interview on NPR’s Fresh Air, John Villasenior at the Brookings Institution revealed that beginning May 2012, US federal agencies, such as law enforcement, will be able to use small undetectable drones to monitor US citizens. These drones can intercept wireless communications coming from smart meters, Wi-Fi, or cell phones. 4 While US citizens can choose wired Internet connections and landlines to limit their surveillance vulnerability, Maryland residents currently cannot turn off or opt out of smart meters; thus they are vulnerable to drone monitoring. Utilities claim they won’t sell the data they will store, even though the information is a marketing pot of gold. We’ll see…Regardless, in the fall of 2015, companies will be permitted to operate drones and third parties will easily access a wealth of information about private behavior in our homes thanks to wireless smart meters.5 Wireless smart meters also pose security concerns. Television shows and media accounts have revealed threats from hacking and terrorism to the smart grid. These concerns are also documented by the Department of Homeland Security and the National Security Agency. Former CIA Director James Woolsey accounted the wireless security threat at http://www.metacafe.com/watch/4260978/jim_woolsey_grid_security_is_afterthought/ More cybersecurity information is outlined in the Congressional Research Report, Smart Meter Data: Privacy and Cybersecurity. Health Concerns Independent scientists and engineers have for many years expressed their deep concerns about the inadequacy of the current FCC (Federal Communications Commission) radiofrequency radiation human exposure guidelines. These guidelines are thermally-based and only warrant protection for the public for up to 30 minutes, and workers for up to 6 minutes at a time. Since pulsed radiofrequency radiation from wireless smart meters emit non-thermal radiation 24 hours a day, seven days a week, many experts believe the FCC guidelines are not sufficiently protecting the health and safety of the public against the chronic, low level, and cumulative exposure conditions people are now being exposed too. In February 2011, the International Electromagnetic Fields Alliance announced the Seletun Statement, a report published by international scientists that urges governments to follow
4 Drones Over America: What Can They See, National Public Radio’s Fresh Air Show, March 12, 2012
http://www.npr.org/2012/03/12/148293470/drones-over-america-what-can-they-see

5 Ibid, Drones Over America: What Can They See?

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Cases 9207 and 9208 Maryland Public Service Commission Comments

significantly lower human exposure standards for electromagnetic fields. Based on power density measurements, the Scientific Panel found sufficient evidence that adverse health effects exist at as low as 0.17 mW/ m². This amount is approximately 50,000 – 60,000 times lower than the current ICNIRP/FCC standards. Smart meters have caused health problems throughout the US. In May 2011, the World Health Organization determined that radiofrequency electromagnetic fields emitted from wireless devices are a class 2B possible human carcinogen, in the same class as lead, DDT, and chloroform. The American Academy of Environmental Medicine opposes the installation of wireless smart meters based on the current medical literature. People across the United States with AMI smart meters on their homes are reporting ringing in the ears, insomnia, strong headaches, nausea, heart palpitations, memory loss, anxiety and pain which began occurring after smart meters were installed. Some people are electrosensitive and can’t tolerate any form of pulsed radiofrequency radiation. You can read individual’s reports about the health effects of smart meters at http://emfsafetynetwork.org/?page_id=2292. Since smart meters are a new technology, there is no scientific literature about the health risks of these devices. But in a memo about smart meters from Poki Stewart Namkung, M.D. Health Officer at the Santa Cruz Health Services Agency to the Santa Cruz County Board of Supervisors, Dr. Namkung stated, “evidence is accumulating on the results of exposure to RF at non-thermal levels including increased permeability of the blood-brain barrier in the head (Eberhardt 2008), harmful effects on sperm, double strand breaks in 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).” There are more scientific studies noted in the Appendix. Wireless smart meters are capable of interfering with implanted medical devices. According to Gary R. Olhoeft, SBEE and SMEE (MIT) and Ph.D. (Physics, University of Toronto), and current Professor of Geophysics at Colorado School of Mines, smart meters can interfere with sensitive medical implants such as deep brain stimulators for Parkinson’s disease and pacemakers. He has experienced this type of interference and set up his home to minimize RF exposure. During a Black Hat security conference in August 2011, a security researcher who has diabetes demonstrated on stage how a third party can transmit wireless commands to remotely disable his insulin pump. The pump accepted and followed commands from any wireless source. Interference, Billing, and Fire Concerns Smart meters interfere with a variety of household wireless gadgets such as garage door openers, Wi-Fi, security systems, cordless phones, wireless headsets, patio speakers, and baby monitors as reported in California and Maine. For example, the Maine Public Advocate’s office announced on November 19 that smart meters installed by Central Maine Power are causing interference with a
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Cases 9207 and 9208 Maryland Public Service Commission Comments

wide range of wireless devices in the home, such as garage door openers, electric fences, Wi-Fi, and security systems. http://www.pressherald.com/news/electronics-on-the-fritz_-could-besmart-meters_2011-11-19.html Improper installation of or faulty smart meters have lead to fires, inaccurate billing, and damages. These stories have been reported in California, Florida, Virginia and Texas.
• http://www.wfaa.com/news/Fires-Spark-During-Smart-Meter-Installations-101115429.html • http://www.click2houston.com/news/28147128/detail.html • http://www.zacks.com/research/get_news.php?id=123e2577

• http://emfsafetynetwork.org/?p=4904

Questionable Energy Savings While utilities claim energy savings from smart meters, the Connecticut Office of Attorney General issued a letter on February 8, 2011 indicating no overall decreased energy usage in a pilot test with smart meters as compared to existing analog meters. A similar study covering one year of smart meter usage in England came to the same conclusion. We believe that an opt-out program should include a provision enabling utility customers to retain analog meters at no additional cost, as long as customers communicate their electric meter readings to utilities once a month. It can be as easy as taking a picture of the analog meter and emailing it to the power company. The service structure for analog meters is already in place, so it can be maintained in the future. The costs of operation of the wireless infrastructure such as the increased demand for electricity to power the wireless meters, educational campaigns, and smart meter installations will be spread across all ratepayers, i.e., those with wireless meters and those who choose to keep their current meters. The cost for retaining a current meter should be treated the same way. Of significant concern is that opt out fees in California, Nevada, and Maine are at least in part designed to deter those who are considering opting out. The fees should not be intended to discourage ratepayers from choosing to keep their current meter. It is inappropriate that an optout fee becomes a de facto deterrent to making that choice, especially for low-income ratepayers whose health and well being may be adversely impacted by a wireless meter. In Maine, Ed Friedman has filed a case arguing that ratepayers who retain their analog meters should not pay initial or additional monthly utility fees.

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Cases 9207 and 9208 Maryland Public Service Commission Comments

Please preserve the individual rights of your ratepayers. By allowing customers to retain their analog meters at no additional cost, you will uphold our founding father’s principals of individual rights. Please join the states of California, Nevada, and Maine by permitting a smart meter opt-out program and improve on those programs by ordering utilities not to charge additional costs to ratepayers retaining their analog meters in Maryland. Thank you for the opportunity to share my views on this important topic. Sincerely,

Christine M. Hoch Executive Director

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Cases 9207 and 9208 Maryland Public Service Commission Comments

Appendix Citing Scientific Studies and Policy Statements
Radiofrequency (RF) radiation and health impacts • WHO International Agency for Research on Cancer (IARC) classifies RadiofrequencyElectromagnetic Fields as a 2B (Possible) Human Carcinogen (5/31/11) www.iarc.fr/en/media-centre/pr/2011/pdfs/pr208_E.pdf This is the same kind of RF-EMF as smart meters produce and at equivalent levels to those on which the IARC finding was made.

Scientific studies and policy statements on links between exposure to RF radiation and health impacts: • Seletun Scientific Statement published in Reviews on Environmental Health 2010 OctDec;25(4):307-17. This report published by a consortium of international scientists urges global governments to adopt significantly lower human exposure standards for electromagnetic fields. The recommendations are based on the latest body of evidence in biological sciences, and the public health implications of the unprecedented global exposures to electromagnetic fields from telecommunications and electric power technologies. Text at: http://international-emf-alliance.org/index.php/publications/seletunresolution

• Pathophysiology Electromagnetic Fields (EMF) Special Issue Volume 16, Issues 2-3, Pages 67250 (August 2009) http://www.sciencedirect.com/science/journal/09284680/16/2-3 From the Preface to this Special Issue: This special issue of Pathophysiology includes scientific papers on the EMF issue by contributors to the BioInitiative Report, as well as others, and is prepared for scientists who are not specialists in bioelectromagnetics.

• “Effects of RF Radiation on Human Health and Disease.” Non-thermal biological effects of RF radiation exist and occur at doses previously thought to be safe. Thermal effects alone should not be considered an acceptable readout of biological effects.” http://tinyurl.com/7yqhh3p

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Cases 9207 and 9208 Maryland Public Service Commission Comments

• “Changes of Clinically Important Neurotransmitters under the Influence of Modulated RF Fields.” http://www.buildingbiology.ca/pdf/rimbachstudy.pdf

• “Nerve Cell Damage in Mammalian Brain after Exposure to Microwaves from GSM Mobile Phones.” http://ehp03.niehs.nih.gov/article/fetchArticle.action?articleURI=info%3Adoi%2F10.1289% 2Fehp.6039#abstract0

• In Sweden, electrohypersensitivity (EHS) is an officially fully-recognized functional impairment http://iopscience.iop.org/1755-1315/10/1/012005

• Listing of studies of studies which demonstrate a nexus between EMF and adverse health impacts and/or the development of thermal or non-thermal effects which may lead to health problems http://www.heartmdinstitute.com/wireless-safety/scientific-research

• Parliamentary Assembly of the Council of Europe (PACE) policy statement regarding dangers of RF radiation to humans http://assembly.coe.int/Main.asp?link=/Documents/AdoptedText/ta11/ERES1815.htm

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Cases 9207 and 9208 Maryland Public Service Commission Comments

Certificate of Service
I, Christine M. Hoch, hereby certify that an original and 17 copies of these comments from the Center for Safer Wireless regarding case 9207 and 9208 were sent via overnight mail on Thursday, April 5, 2012 to David J. Collins, Executive Secretary, Maryland Public Service Commission, William Donald Schaefer Tower 6 St. Paul Street, 16th Floor, Baltimore, MD 21202 _________________________ Christine M. Hoch _______ 4/5/12

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