Traci M.

Radice

April 5, 2012

Public Service Commission of Maryland Attn: David J. Collins, Executive Secretary William Donald Schaefer Tower 6 St. Paul Street, 16th Floor Baltimore, MD 21202-6808 RE: Case No. 9208 (Opt out of installation and use of Smart Meters)

Dear Mr. Collins: I write to you today as a concerned resident of Maryland, and on behalf of my family, regarding the mandatory installation of Smart Meters and the right to be allowed to deny the installation of them. Why should Marylanders be subjected to an experiment that has proven unsuccessful? Why should Marylanders be exposed involuntarily to EMF radiation unnecessarily? What makes Maryland unique when compared to the other states that are mandating moratoriums or allowing opt-out programs? I implore the PSC to read all of the materials submitted by non-utility companies and published materials in other states, and, in so doing, it will have no choice but to find that an opt-out requirement is in the public's interest. My concerns and questions are as follows: Safety and Health Without adequate testing, the PSC cannot allow mandatory installation ora Smart Meter on a customer's home. There is too much data supporting illness, privacy issues and risk of fires, and no data supporting their safety. Has BGE provided any testing results of the Smart Meters it intends to install? That is, actual results of testing for any safety defects, etc. that could lead to fire, as well as, actual test results that the harmful EMF radiation pulsing through my home 24/7 will not lead to any member of my family becoming ill. There is evidence in other states that many Smart Meters were found to be defective AFTER the installation (and after the meter caused damage to the property) because the meters were not adequately tested PRIOR to installation. Risking the lives of Marylanders is NOT in the best .interest of the PSC or the pu blic' s interest. Note that the defective meters will cause fire damage resulting in an increase in property

Mr. David J. Collins April 5,2012 Page 2

insurance

claims.

Even the non-defective meters are proven to cause illness, which will result in an increase in health insurance claims. Can BGE guarantee my house will not catch fire from the installation of a Smart Meter, as has occurred in AL, GA and CA? Ifthe answer is anything other than a solid guarantee, these meters should NOT be mandatory and pushed upon Marylanders without our consent. There have been numerous fires as a result of the installations of smart meters in other states. Insurance companies have hired independent laboratory scientists who observed cell damage and DNA chain breaks [as a result of smart meters], and now the insurance companies will not insure liability damage from wireless smart meters and other wireless devices. According to the American Academy of Environmental Medicine, current medical literature raises serious questions about genetic, cellular and hormonal effects, blood/brain barrier damage, and increased risk of certain types of cancers as a result of exposure to this radiation. Children are at risk for altered brain development, impaired learning and behavioral problems. In fact, in its January 19,2012 letter to the California Public Utilities Commission, it advised that "chronic exposure to wireless radiofrequency radiation is a preventable environmental hazard that is sufficiently well documented to warrant immediate preventative public health action." In addition, according to the Interagency Working Group (a federal interagency group which includes members from the FDA, FCC, OSHA and the EPA) the FCC safety limits for RF radiation are "not protective of public health." Evidently, FCCguidelines are inadequate for use in establishing public health standards because the existing FCCguidelines for RF safety that have been used to justify installation of smart meters are outdated and obsolete, as they do not reflect current studies of the metabolic and genomic damage from RF and ELF exposures below the level of intensity which heats tissues ..... The accumulation over time is the key here, given the chronic nature of exposure from a smart meter." The AAEM urges consideration of a moratorium on installation of wireless smart meters until "the serious public health issues are resolved", and that "continuing with their installation would be extremely irresponsible." Dr. Carpenter, public healthy physician and former Dean of School of Public Health at the University of Albany, in a public letter dated Feb. 21, 2012 advised that "the difference between a cell phone and a smart meter environment is that while the cell phone is used only intermittently a smart meter environment is continuous." Further, there have been no studies of the health effects of smart meters to knowledge. The important thing to remember here is "cumulative, aggregate exposure." (See letter from Dr. Carpenter dated 02/21/12).

Mr. David J. Collins April 5, 2012 Page 3

Has Maryland requested the Health Department/Services Agency(ies) to conduct an analysis of the research on the health effects of SmartMeters? The Santa Cruz County (California) Board of Supervisors requested an analysis from the county's Health Services Agency ("agency"). (See. http.y/emfsafetynetwork.org/wpcontent/uploads /2009/ 11/H ealth -Risks-Associated -With-S martMeters. pdf.) The agency commented that to analyze the potential health risks associated with SmartMeters, 3 questions need to be asked: 1) What is the SmartMeter from the system? system and what is the potential radiation exposure

2) What scientific evidence exists about the potential health risks associated with SmartMeters? 3) Are there actions that the public might take to mitigate any potential harm from SmartMeters? All] have seen from the PSC and BGE are financial in nature, e.g., billing rates, energy savings, installation schedule tariff rate, etc. Nothing in the PSC's notice of hearing addressed the very real health risks to Marylanders. The agency noted that there is no scientific data to determine if there is a safe RF exposure level regarding its nonthermal effects (the FCCguidelines are irrelevant and cannot be used for any claims of Smart Meter safety because the current FCCguidelines were adopted in 1996 and are thermal based). Absent any scientific studies, this is a completely risky experiment and poses very real dangers to living beings. Finally, the agency called upon all governmental agencies for protecting public health and safety to be more vigilant towards involuntary environmental exposures. Program Manager for the Power Plant Research Program, along with Doreen Hill, Ph.D. of Hill Consulting, submitted a status report to the PSC on the potential human health effects associated with EMF (See
http.Z/esm.versar.com/pprp /bibliography /PPSE· T-44/Final%202006%20%20 EMF%20Report.pdf).

In October, 2006, Sandra S. Patty, Transmission

Besides the multitude of inconsistencies in the report, it was noted that the Draper, Kroll & Swanson study found increases in acute leukemia at lower levels than in previous reports. Having that data before you from 2006, and knowing there is more evidence today, you cannot disagree that more research needs to be done before exposure to living creatures - especially mandatory exposure.

Mr. David J. Collins April 5, 2012 Page 4

Regarding the utility companies' representations that the meters will be asleep 99% of the time, a PEPCa technician recently conducted a test and stated that the meter was in fact sending out thousands of pulses per day and that the PEPCa website which states that "smart" meters are broadcasting six times per day and are asleep 99 percent of the time was in error. The other three PEPCa employees present [at the time] agreed with this statement. The PEPCa technician said that the data on the website is what the manufacturer of the meter had told PEPca. BGE indicates that the meters only transmit for less than 2 minutes per day. Has BGE tested its meters? Are they different from PEPCa's? According to Pacific Gas and Electric (CA), approximately 180,000 people will choose to opt out for health reasons. If the numbers in Maryland match, then at least 30,000 BGE customers may experience similar health effects. I hope the PSC prepares the State and the court system for the numerous class action suits that will undoubtedly be filed statewide. Invasion of Privacy Can BGE guarantee that my personal data will NEVER reach the hands of third parties? Can you guarantee that BGE's records will never get hacked by third parties and my personal data exposed? No, of course not, and that is another reason that customers should be allowed to opt out. Smart meters capture personal data. BGE employees and outside vendors will know whether we're home or not, and if our alarm system is activated or not. Evidently, in a second phase, household appliances will have RFID chips, which will communicate wirelessly with our smart meters, adding another layer of radiation into our home. Smart meter appliances will tell the utility about our personal energy usage and habits. This data may then be sold to marketing firms. No regulations are in place to prevent any of this, nor are there ANY ways to guarantee this information will not be hacked and/or used for identity theft and/or billing fraud. My constitutional right to privacy in my home outweighs ANYTHING the utility companies, or the PSC, allege will be a benefit (to them). Cost savings Despite the fact that BGE promises lower rates, where are BGE's actual studies which prove a savings in energy and costs? In fact, BGE admits it has not done a complete cost of service study to support its estimates. Rather, ratepayers in Santa

Mr. David J. Collins April 5, 2012 Page 5

Cruz, CA and in other states have complained installation of a smart meter.

about INCREASES in their rates after the

Aside from that, however, if you ask any ratepayer whether he/she would be willing to risk his/her life to save a few dollars, they'd choose to opt out.

Wired alternative Ifthe Smart Meters are going to be installed against the public's consent, why can't BGE install wired meters which are proven safer to the lives and homes of Marylanders? There is a way to have a smart grid system with no wireless technology. Meters would simply be hardwired into the existing telephone system. Some Vermont utilities have already done that in pilot programs and are reporting successful outcomes. Allowing an opt-out option As of the date of this letter, the Public Service Commissions in Maine, California and Nevada have adopted opt-out programs, however, at least in California, it was done AFTER there was evidence of illness and property loss. Some cities and counties have even mandated moratoriums. Other cities, counties, states are gearing up to do the same. Said CPUC President Michael R. Peevey, "The standard for metering has been transitioning worldwide from the older technology of analog meters to today's Smart Meter technology. We are not reversing that transition by allowing for an analog optout, but we are recognizing that certain customers prefer an analog meter." And, added Commissioner Timothy Alan Simon, "Tcday's decision provides a choice to customers who would like to opt-out of PG&E's Smart Meter installation program at a much lower costs than originally proposed. It is a great example of how public initiative and participation can result in better regulatory policy." From Maine - Commissioner Vafiades said: "Based on sound public policy, as allowed by statute and taking into consideration all public correspondence and filings, we conclude that offering a smart meter opt-out options is reasonable and in the public interest." Why should the Maryland PSC stand any differently? Lastly, if the PSC allows customers to opt out, I implore the Commission to allow it at no charge. If [ do not pay a surcharge or monthly fee for my analog meter now, why on Earth would [ have to be charged to retain it when BGE installs Smart Meters throughout the states? If part of the reason for Smart Meters is to eliminate meter readers in the field, why are we not paying a surcharge now for the employees in the

Mr. David J. Collins April 5, 2012 Page 6

field? Why eliminate the field position and add to unemployment'? Why not allow them to keep their jobs and continue reading our analog meters for free like they are doing now? Makes no sense to start charging customers for something they've been getting for free for years. Why am I writing? In the words of Martin Luther King, Jr. "Our lives begin to end the day we become silent about the things that matter." I urge the PSC to consider the mistakes made by other utility companies across the United States that rushed into a highly questionable, technological fiasco. The PSC should do the right thing for the citizens of Maryland, i.e., allow an opt-out option (at no cost) for people who do not want the Smart Meters installed on their homes and businesses. Sincerely,

Traci M. Radice PARALEGAL

1 Maryland's unemployment rate was at 6.5% in January, 2012. The utility companies with the installation of SmartMeters.

are adding to that