August 4, 2013 Ronald M. Powell, Ph.D.

Contents of Smart Meter Package

Impact of Smart Meters on Montgomery Village

Concerns about Wireless Smart Meters

Attachment No. 1 Statement of the American Academy of Environmental

Medicine, cautioning against Smart Meters

Attachment No. 2 Letter from the American Academy of Pediatrics,

stressing the vulnerability of children and pregnant
women to radiofrequency radiation and advocating
action by the U.S. Congress in response

Attachment No. 3 Biological Effects from RF Radiation at Low-Intensity

Exposure, based on the BioInitiative 2012 Report,
and the Implications for Smart Meters and Smart
Appliances

Attachment No. 4 FCC Maximum Permissible Exposure Limits for

Electromagnetic Radiation, as Applicable to Smart
Meters

Attachment No. 5 Form letter to PEPCO to request removal of a Smart

Meter

Attachment No. 6 Sign to post on a Smart Meter when requesting its

removal by PEPCO

Attachment No. 7 Brochure of Maryland Smart Meter Awareness

August 1, 2013 Ronald M. Powell, Ph.D.

Impact of Wireless Smart Meters on Montgomery Village

Background

Montgomery Village rightly prides itself on offering a remarkable quality of life for its residents. Sadly, that
quality has been substantially degraded in recent months by an increase in microwave radiation. The local
electric power company, PEPCO, passed through MV in late 2012 and early 2013, and installed an
estimated 12,000 wireless Smart Meters, one on each residence in MV. These Smart Meters are digital
watt-hour meters combined with wireless microwave transmitters and receivers. Each Smart Meter
transmits pulsed microwave signals with a microwave power output of about 1 watt. So the installed Smart
Meters represent about 12,000 watts of microwave transmission capability, embedded intimately in our
residential community. The Smart Meters generate and transmit to PEPCO, or its agents, a detailed profile
of the electric power consumption of every residence in MV, around the clock, every day of the year,
indefinitely. The Smart Meters also communicate with each other, in what is called a mesh network, and
forward data along to PEPCO or its agents. Based on a California court document, describing equipment
from the same manufacturers used by PEPCO in MV, each Smart Meter transmits an average of 10,000
times per day, and a maximum of 190,000 times per day. For MV’s 12,000 Smart Meters, that means an
average of 120 million transmissions per day, and a maximum of 2.3 billion transmissions per day.

PEPCO’s claimed benefits for Smart Meters can be found at

http://www.pepco.com/energy/blueprint/smetersmd. PEPCO’s main argument for Smart Meters has been
that customers can reduce their energy consumption by studying the data that PEPCO collects from their
Smart Meters and posts on PEPCO’s web site for each customer’s account.

Capabilities

Smart Meters have many capabilities. Smart Meters contain switches that enable PEPCO to turn off the
electric power to your home, merely by sending a microwave signal to your Smart Meter. Smart Meters
can send microwave signals throughout your home to communicate with emerging Smart Appliances that
will have their own microwave transmitters and receivers. Your Smart Meter will identify which Smart
Appliances you own, when you use them, and how much power each consumes, around the clock, every
day of the year. Smart Meters may even be able to turn these appliances off when so ordered by a wireless
signal from PEPCO, but that is less clear at this time. Smart Meters can be reprogrammed remotely by
PEPCO to perform additional functions not yet known to the customers, and not subject to their approval.

Concerns

Wireless Smart Meters give rise to a number of concerns:

1
Health

Smart Meters are everywhere in MV, and the microwave radiation that each Smart Meter transmits
extends far beyond the boundaries of the property on which it is installed. So there is no place in MV
where you can go without being exposed to increased microwave radiation generated by Smart Meters.
Every room of every home, every crib, every playground, every school, every pool, every walkway, every
roadway, every church and synagogue, and every business is subject to an increase in microwave exposure.
And this increased exposure is occurring just as the international medical research community is finding
that humans are much more sensitive to harm from microwave radiation than earlier understood. That
sensitivity extends down to levels easily produced by just one Smart Meter or just one Smart Appliance, for
individuals close enough to them, let alone many of them.

Major medical organizations are warning about the adverse impact on human health of the thoughtless
expansion of wireless technology. They include the American Academy of Environmental Medicine,
composed of medical doctors that address the impact of the environment on health, and the American
Academy of Pediatrics, whose 60,000 member doctors care for our children.

Sadly, the FCC’s present Maximum Permitted Exposure limits, that govern Smart Meters and other wireless
devices, are too high (too permissive) to protect the public. Those FCC limits are based principally on a
1986 analysis, now 27 years old, that predated both most of the microwave devices being regulated,
including Smart Meters, and most of the research on the biological effects of microwave radiation. The
deficiency of the present limits has been recognized in a bill before the U.S. House of Representatives,
H. R. 6358, that would support research toward better founded limits for wireless devices. But the
development of more protective limits, if ever undertaken, will take years. In the meantime, the public has
been left on its own to endure the consequences. And the pending arrival of Smart Appliances, which will
be purchased unwittingly by the public, is going to make the situation much worse.

Smart Meters are too much like a giant uncontrolled medical experiment, in which all of us have been
enrolled, without informed consent, or any consent at all.

Security

The power profile, collected by Smart Meters and transmitted throughout the day to the power company
or its agents, will be sufficient to determine when you are home, when you are away, when you get up in
the morning, and when you go to bed at night, thus decreasing personal security. Also, like all wireless
networks, Smart Meters will be susceptible to cyber attack, possibly disrupting the continuity of electrical
power to your home and the proper recording of your electricity consumption for billing purposes.

Privacy

In our electrical society, much can be learned about the activities occurring in your home from your
electric power profile, since just about every type of electrical device, such as a refrigerator, a television
2
set, or a computer, has a unique power profile. This identification will become more exacting as the Smart
Appliances are put into service. Advertisers may want your profile to determine which appliances you own.
Data miners may want your profile for marketing or other purposes. Law enforcement may want your
profile for surveillance purposes. And there is currently no law that prevents the sale or transfer of your
personal information to anyone.

Hidden Costs and Doubtful Benefits

The State Attorneys General of Illinois, Connecticut, and Michigan have decried the costs of Smart Meters
because no commensurate financial benefits to the customers have been convincingly demonstrated.

Property Values

It is early to predict the impact of Smart Meters on an entire community, like MV. But California provides
an early indicator. Smart Meters were installed there beginning several years ago, so California is farther
along in consideration of the consequences. Since then, 57 counties, cities, and towns in California have
opposed mandatory installation of Smart Meters in their jurisdictions. And, a growing number of these
jurisdictions, 15 of the 57, have passed ordinances prohibiting Smart Meters altogether. Families looking
for a home may prefer to live in a community that has already eliminated Smart Meters, for health or other
reasons. This inclination has the potential for depressing property values, and eroding the tax base, in
communities that decide to retain Smart Meters. At the same time, this inclination has the potential for
increasing property values, and expanding the tax base, in communities that eliminate Smart Meters.

What Can Village Residents Do?

The arrival of Smart Meters has provoked the Maryland public sufficiently that the Maryland Public Service
Commission has offered a temporary right for individual homeowners to Opt Out. That is, homeowners
may have their Smart Meters removed and replaced with safe, reliable, traditional analog mechanical
meters. Unfortunately, most MV residents do not know that they have a Smart Meter, or what risks it
entails, or that they have a right to have it removed. So the right to Opt Out will be underutilized by
residents, leaving MV exposed to the extra microwave radiation of Smart Meters for the indefinite future.
Unfortunately, too, even if all residents willing to study up on Smart meters do Opt Out, there will be so
many Smart Meters remaining that microwave radiation levels throughout MV will remain elevated. All of
these factors add up to the need for an MV-wide Opt Out. Obtaining that is going to require leadership at
both the community level and the MV level.

What Can Village Managers Do?

Study this issue to determine for yourselves the merits of the concerns. If you wish, start with the attached
tutorial, Concerns about Smart Meters, written in a neighbor-to-neighbor format. That tutorial is followed
by several attachments that expand upon information in the tutorial.

3
Visit and read the materials on the web site http://MarylandSmartMeterAwareness.org. This organization
is a non-profit, public-spirited group of Maryland volunteers with more than 500 members. They represent
many fields, including doctors, scientists, engineers, computer experts, lawyers, and concerned parents
broadly. They are not anti-technology; in fact, many of them have spent their careers developing advanced
technology. Rather, they recognize an unwise use of technology when they see it. They are working hard
to educate Marylanders about the serious consequences of Smart Meters.

Search the Internet for information about Smart Meters. Recognize that the opposition to Smart Meters is
nationwide, with half or more of the states now participating. Appreciate the fact that Maryland has
provided an Opt Out. (DC and Pennsylvania have not, but one power company in Virginia has voluntarily
offered an Opt Out).

If, after your inquiry, you judge that Smart Meters are not good for you or MV, Opt Out yourselves, both to
reduce the risks to your families, and to set a good example for other MV residents. Inform MV residents
about Smart Meters through an article in the Village News and, better yet, through an upcoming MV-wide
mailing; and urge MV residents to Opt Out.

Write the Maryland Public Service Commission to support its temporary Opt Out privilege and to urge an
indefinite extension. Contact the Maryland State Senators and Delegates that represent MV, and the
members of the Economic Matters Committee of the House of Delegates, in support of HB1038, which is
currently before the Committee. If HB1038 becomes law in the 2014 session, HB1038 will make the right to
Opt Out permanent, will prevent any fee from being charged to those opting out, and will protect data
collected by Smart Meters from being sold to others.

Then address the big task: pursuing an MV-wide response to Smart Meters, to protect our entire
community.

Closing

The regrettable decision to install wireless Smart Meters in our community can be reversed by people of
good will and determination. But only if we act together and soon. If we do not, we will have to bear the
consequences of our inaction for years to come. That would be a tragic and unnecessary outcome.

4
August 1, 2013 Concerns about Wireless Smart Meters Ronald M. Powell, Ph.D.

PEPCO Recently Installed a Wireless Smart Meter

on Your Home
The Bad News: You May Not Want One on Your Home
The Good News: You Can Have It Removed by Sending a
Letter to PEPCO, as Many Neighbors Have Done
PEPCO has replaced all traditional analog mechanical power meters with wireless digital Smart Meters on all
homes in the PEPCO service area. A similar replacement is underway in many other U.S. states, and in other
countries, too. Installation of Smart Meters in Montgomery Village was underway in late 2012 and early
2013.

PEPCO=s reasons for installing wireless Smart Meters are described here:

http://www.pepco.com/energy/blueprint/smetersmd

Some of the intentions are good. But there are significant concerns, too. The purpose of this document is
to describe the concerns so that you can decide for yourself about retaining your Smart Meter. These
concerns include health, privacy, security, fire safety, hidden costs and doubtful benefits to the consumer, and
the impact on our community as a whole.

These concerns have arisen in many states, and in many countries, too. In Maryland these concerns have
been sufficiently great that Maryland permits you to have your wireless Smart Meter removed, through what
is called an OPT OUT. Many of your neighbors have already OPTED OUT, and more are in the process of
doing so now. You may wish to do so, too. Maryland=s OPT OUT permission is currently temporary and the
duration is not known. But a new bill, HB1038, is currently before the
Maryland House of Delegates to make the OPT OUT permanent and to
provide other protections for Marylanders. All of this is discussed here.

What is a Wireless Smart Meter?

Wireless Smart Meters combine a wireless microwave transmitter and a
wireless microwave receiver with a digital watt-hour meter. Smart Meters
are made by many different manufacturers and thus can have many different
appearances, but they all seem to have digital displays. That is, they display
individual numerical digits rather than round dials, that look like clock faces, from which the digits are read.
The principal type of wireless Smart Meter that PEPCO is installing in our community is the FOCUS AXR-SD
made by Landis+Gyr. It is pictured here.1 However, some homes in our community are receiving the

1
“Product Specification Sheet - E330 Focus AX + E350 AX-SD Single Phase” found on the web site of the manufacturer, Landis+Gyr:
( http://style.landisgyr.com/apps/products/data/pdf1/FOCUS_AX_SDSheet.pdf ).
1
I-210+c, made by General Electric. It is pictured next.2 In our community,
this GE meter has a gray plastic cover over the top of the meter, so it looks
somewhat different from the picture shown here.

The basic function of any watt-hour meter is to measure the electrical energy
that you use so that you can be billed once a month. But the new Smart
Meters have many capabilities that go well beyond this simple function, and
the implications of those capabilities have not been well explained to the
public. Here are the capabilities that I know about, to date:

The Smart Meters report your power usage to PEPCO, not just once a month, which would be sufficient
for the type of billing used until now, but rather periodically throughout the day and the night, every
day and every night of the year, for the indefinite future. Each Smart Meter does this by sending
microwave signals to PEPCO from a transmitter inside the Smart Meter.

The Smart Meters receive commands that PEPCO sends to them. Each Smart Meter is equipped with
a microwave receiver for this purpose. The Smart Meters give PEPCO the capability to shut off your
electric power, remotely, by sending a microwave signal to your home. The Smart Meters can also be
remotely programmed to perform new functions by sending microwave signals to them.

New ASmart Appliances@ will become available this year. The Smart Appliances will contain
microwave transmitters and receivers of their own. The Smart Meters and the Smart Appliances will
be able to communicate with each other by sending microwave signals throughout your home. The
Smart Meters will enable PEPCO to identify which Smart Appliances you have in your home, when you
put them into service, when and how much you use each of them every day and every night, and when
you take them out of service. The Smart Meters may also enable PEPCO to send signals to your Smart
Appliances to turn them off, but that is less certain at this time.

Wireless Smart Meters can send microwave signals to other wireless Smart Meters. In fact, they are
linked together in a so-called mesh network. One purpose of this mesh network is to assure that data
about your power consumption and your Smart Appliances reaches PEPCO even if your signal does not
reach PEPCO=s receivers directly. So your Smart Meter will be busy transmitting and receiving data
from your neighbors= Smart Meters. And your neighbors= Smart Meters will be busy transmitting and
receiving data from your Smart Meter. These Smart Meters will also be busy sending signals to each
other to keep them Asynchronized@ with each other in the mesh network.

Some Smart Meters play a special role in the mesh network. They are called Collector Smart Meters.
These wireless Collector Smart Meters are especially busy receiving, storing, and transmitting other
peoples= data as well as your own. At this time, I do not know if Collector Smart Meters are employed
in PECCO’s implementation of Smart Meters in Maryland. If Collector Meters are being employed, I
have not heard whether PEPCO will notify homeowners that their Smart Meter is a Collector Smart
Meter.

In sum, each Smart Meter performs communications services that are analogous to those performed
by a cell tower in a cell-phone system: receiving microwave signals, transmitting microwave signals,
and relaying data via microwave signals. In this sense, each Smart Meter functions like a mini cell
2
“Residential Electrical Metering, Advanced ANSI metering solutions for the smart grid”, GE Digital Energy, found on this web site:
( http://gedigitalenergy.com/SmartMetering/brochures/I-210PC.htm ).
2
 tower erected on your property. The Smart Meters are very busy. California court documents
indicate that the Smart Meters in use there make an average of 10,000 transmissions per day, and a
maximum of 190,000 transmissions per day.3 The manufacturers of those Smart Meters, and the
associated wireless networking equipment, also make the equipment that PEPCO is installing in our
area.

How Does a Traditional Analog Mechanical Meter Compare with a Wireless

Smart Meter?
A traditional analog mechanical meter, pictured here,4 serves
only one purpose: It records the electrical energy consumed
for the purpose of billing the customer once a month. It does
not transmit wireless signals to remote locations; it does not
receive wireless signals; and it is not subject to interference by
wireless signals. It does not communicate with Smart
Appliances, and it does not generate data about your use of
your appliances. These traditional meters have proven their
reliability and accuracy over the years, and they are
inexpensive to manufacture. These traditional meters are
read periodically by a meter reader on foot.

Some variations of the traditional analog mechanical meter do exist, and I am not certain which of these, if
any, are present in our community. Some of these variations contain electronic modules that enable PEPCO
to read them remotely from the street by interrogating the modules with a wireless signal. There may be
other variations that contain electronic modules that report the meter reading more frequently by wireless
means. So there may be some meters in service in our community that are part way between the traditional
analog mechanical meter with no wireless capability, and a Smart Meter with extensive wireless capability.

What are the Concerns about Wireless Smart Meters?

The new capabilities of Smart Meters have given rise to concerns across Maryland and, indeed, in other states,
too. In fact, the residents of half or more of the states are currently engaged in battles over the installation
of Smart Meters.5 A wide variety of concerns have been expressed. Here are six of the concerns.

Concern No 1: HEALTH

The new wireless Smart Meters contain microwave radio transmitters and receivers that transmit and receive
bursts of microwave radiation periodically, throughout the day and the night, every day of the year, for the
indefinite future. The Smart Meters radiate in every direction, including into, and throughout, your home.
3
Pacific Gas and Electric Company’s Response to Administrative Law Judge’s October 18, 2011 Ruling Directing it to File Clarifying
Radio Frequency Information. See Response 2 to Judge’s Question 2, shown on page 5. PG&E (serving California) employs Smart
Meters and internal microwave transmission/reception electronics made by the same manufacturers as those installed in
Montgomery Village (Landis+Gyr and General Electric for the meters, and Silver Springs Network for the modules). The exact
numbers, before rounding, are an average of 9981 transmissions per day, and a maximum of 190,396 transmissions per day, for
each meter. ( http://www.centerforsaferwireless.org/documents/PGERFDataOpt-outResponse2011.pdf )
4
( http://stopsmartmeters.org/frequently-asked-questions/photos-of-analog-meters )
5
( http://www.scribd.com/doc/100365955/Actions-Opposing-Smart-Meters-Across-the-United-States ) and
( http://takebackyourpower.net/worldwide-directory/usa )
3
They do this to assure that the signals reach PEPCO, no matter where PEPCO=s receivers are located, and to
detect and communicate with any forthcoming Smart Appliances that will be in your home. The result is that
Smart Meters expose the residents, and their neighbors, to chronic microwave radiation, which is proving an
increasing health concern. The amount of microwave radiation in your home will increase further when the
new Smart Appliances arrive, as they, too, begin sending microwave radiation throughout your home. In
effect, Maryland residents have been enrolled, in a massive medical experiment, without informed consent, or
any consent at all.

The full scope of the health hazards of electromagnetic radiation, including microwave radiation, is not yet
fully understood and is the subject of intense medical research worldwide. But enough has already been
learned to stimulate significant concern. Here are several indicators of the level of that concern:

In May 2011, the World Health Organization classified electromagnetic radiation as a Class 2B
carcinogen (Apossible carcinogen@), based on the exposure provided by cell phones.6

In April 2012, the American Academy of Environmental Medicine (AAEM) issued a cautionary
statement about wireless Smart Meters.7 A copy of that statement is provided as Attachment No. 1.
The AAEM is the Nation=s leading organization of medical doctors, addressing the impact of the
environment on human health. The doctors in the AAEM indicate that they are already seeing
patients with adverse health effects from wireless Smart Meters. Unfortunately, most medical
doctors, outside of the AAEM, are not trained to recognize the health effects caused by
electromagnetic radiation. Further, doctors may not be able to help affected patients until the source
of the radiation is removed.

In December 2012, the American Academy of Pediatrics (AAP) wrote to the U.S. House of
Representatives to emphasize the vulnerability of children and pregnant women to radiofrequency (RF)
radiation, including cell phone radiation. The AAP urged support of a new bill, H.R. 6358, that would
support the development of new standards for maximum radiation exposure that would be more
protective than the current standards. The AAP is “a non-profit professional organization of 60,000
primary care pediatricians, pediatric medical subspecialists, and pediatric surgical specialists dedicated
to the health, safety and well-being of infants, children, adolescents, and young adults....” The letter
from the AAP to the U.S. House of Representatives is provided as Attachment No. 2.

Also, in December 2012, an international group of 29 M.D.s, Ph.D.s, and other professionals in health
care, from ten countries, issued a 1479-page report entitled ABioInitiative 2012 - A Rationale for
Biologically-based Exposure Standards for Low-Intensity Electromagnetic [email protected] As the basis for
this report, the authors considered the “content and implications of about 1800 new studies” since the
last BioInitiative Report was published in 2007.9 A co-editor selected 67 studies for special attention
in the summary. Those studies found biological effects from radiofrequency/microwave radiation at
low intensities, of the type emitted by cell towers, Wi-Fi, wireless laptops, and Smart Meters. Those
biological effects fell into eight major categories, including: brain cancer and blood-brain barrier
6
You may read the press release of the International Agency for Research on Cancer, of the World Health Organization, on the
Internet: ( http://www.iarc.fr/en/media-centre/pr/2011/pdfs/pr208_E.pdf ).
7
( http://aaemonline.org/pressadvisoryemf.pdf )
8
BioInitiative Working Group, Cindy Sage and David O. Carpenter, Editors, BioInitiative Report: A Rationale for Biologically-based
Public Exposure Standards for Electromagnetic Radiation at www.bioinitiative.org, December 31, 2012.
( http://www.bioinitiative.org )
9
BioInitiative 2012 Report cited in footnote 8 on page 4, Section 1, Summary for the Public and Conclusions, 2012 Supplement:
Summary for the Public – Ms. Sage, page 3.
4
 breakdown; other forms of cancer; cardiovascular effects; oxidative and DNA damage; sleep disruption
and memory/learning/behavior effects; stress proteins and disrupted immune function; and
reproduction/fertility effects. All effects occurred at levels below, or far below, the FCC Maximum
Permitted Exposure limits currently governing Smart Meters and many other microwave devices,
indicating that such high limits provide no protection against these biological effects. And most of the
biological effects occurred at levels of radiation easily produced by the presence of just one Smart
Meter on or near a home, let alone a whole community of them. The full report can be read on line
or downloaded without charge.10 A discussion of the implications of the 67 studies for Smart Meters
and Smart Appliances is provided as Attachment No. 3.

In February 2013, the citizens of Maine presented, to the Maine Public Utilities Commission, both
expert and lay testimony about adverse health effects from the microwave radiation from Smart
Meters. They explained: AExpert testimony is that of scientists engaged in research on the
biological effects of low-level RF or those engaged in public health or policy in this arena. Lay witness
testimony is typically from those sensitive to electricity and/or electromagnetic fields, a condition that
is often referred to as electromagnetic hypersensitivity (EHS) or electrically sensitive (ES).@ You can
read that testimony on the web site of the Maine Coalition to STOP ASmart@ Meters.11

You might ask: If Smart Meters are harmful to human health, why hasn=t the U.S. Government protected us
from them? The answer, at least in part, is that the current Maximum Permitted Exposure (MPE) limits from
the Federal Communications Commission, that govern the electromagnetic radiation from Smart Meters and
other wireless devices, are based primarily on a 1986 analysis that has not been significantly updated since
then. That was 27 years ago, before most of the microwave devices in our environment, including Smart
Meters, were created, and before nearly all of the currently available medical research findings on adverse
biological effects became available. If you would like to know more about the FCC MPE limits, see
Attachment No 4. As an indication of the inadequacy of the FCC MPE limits, there is a bill currently before
the U.S. House of Representatives, H.R. 6358. This bill would support research toward new exposure limits
to protect the public better from harmful levels of electromagnetic radiation. But that process will take
years. In the meantime, the public is on its own. You can read a summary of the bill on the web site of
Maryland Smart Meter Awareness.12 This is the bill mentioned above that is supported by the American
Academy of Pediatrics.

PEPCO could have eliminated the health concern by using a hardwired technology, instead of a wireless
technology, for returning the data from Smart Meters to PEPCO. New digital watt-hour meters that employ
only hardwired technologies are already commercially available. Examples of hardwired technologies are
hardwired telephone lines, hardwired Internet connections, and hardwired cable television lines. A prime
example of such an alternative is the new FIOS optical-fiber system recently installed by Verizon in our
community. It is very safe. Further, Smart Meters are not mobile devices; so they do not require a wireless
approach to achieve mobility.

There may be other wireless microwave devices in your home, such as cell phones, cordless phones, local area
computer networks (including Wi-Fi), and microwave ovens. Yes, they, too emit microwave radiation. But
there is a difference. These devices are under your control. You can control whether you use them or not,
how frequently, and for how long. And you are free to change your mind about such use in the future, as

10 BioInitiative 2012 Report cited in footnote 8 on page 4.

11
( http://www.mainecoalitiontostopsmartmeters.org/2013/02/introduction-to-our-puc-filings-of-expert-and-lay-witness-testimony )
12 ( http://marylandsmartmeterawareness.org/smart-meter-news/ask-your-congressional-rep-to-co-sponsor-h-r-6358 )
5
more is learned about the health effects of microwave radiation. But once a wireless Smart Meter has been
installed on your home, you have forfeited your control over the microwave exposure provided by that Smart
Meter.

It is informative to compare the microwave power output levels of Smart Meters to the microwave power
output levels of other microwave devices that may be in your home.

Device Microwave Power Output

Smart Meter13 1.115 watts which is 1115 milliwatts

Typical leakage from a microwave oven14 1 watt which is 1000 milliwatts
Typical cell phone14,15 0.5 watt which is 500 milliwatts
Wireless LAN (802.11a)14 0.251 watt which is 251 milliwatts
Wireless LAN (802.11n)14 0.250 watt which is 250 milliwatts
Cordless phone16 0.230 watt which is 230 milliwatts
Wireless LAN (802.11 b,g)14 0.100 watt which is 100 milliwatts
Typical laptop wireless LAN (Wi-Fi)14 0.032 watt which is 32 milliwatts

So the Smart Meter=s microwave power output is comparable to the microwave power output of the most
powerful source of microwave radiation in your home: the typical leakage from a microwave oven.
Further, each Smart Meter has twice the microwave power output of the typical cell phone, four to eleven
times the microwave power output of a wireless local area network (LAN), five times the power output of a
cordless telephone, and thirty-five times the microwave power output of the LAN in the typical laptop.
Factors other than power output are very important to the actual exposure received, such as carrier continuity
(continuous versus pulsed, and duty cycle), modulation method (the technique used to place information on
the carrier), the distance from the source, and the presence of intervening structures that may absorb or
reflect the radiated signals, among others. These other factors can be highly variable.

If you think of microwave safety as staying within a Amicrowave exposure budget@ for your home, then the
following question becomes important: Do you value the service that a wireless Smart Meter offers you so
highly that it merits being the largest part of your microwave exposure budget?

You may hear proponents of Smart Meters say: ASince there are other sources of microwave radiation in
your environment, what does one more source matter?@ The response of the opponents of Smart Meters is

13
The FOCUS AXR-SD and the I-210+c both have FCC-ID OWS-NIC514, which indicates that they send and receive information in two
microwave frequency ranges: (1) 902.3 to 926.9 MHZ, and (2) 2405.8 to 2480.9 MHZ. MHZ means millions of hertz. 1 hertz is
one cycle per second. The microwave output power in the first frequency range is 0.968 watts. The microwave output power in
the second frequency range is 0.147 watt. The sum of these two is 1.115 watts. Landis+Gyr and PEPCO declined to answer a
question as to whether the two frequency ranges are used simultaneously. I assume here that they are and have summed their
outputs as a result. If they are not used simultaneously, then the microwave output power would be 0.968 watts.
( http://stopsmartmeters.org/wp-content/uploads/2012/01/OWS-NIC514-FCC-specifications.pdf ).
14
Wikipedia provides data on power levels on the Internet: ( http://en.wikipedia.org/wiki/DBm ). 1 watt is equivalent to 1000
milliwatts.
15
The World Health Organization indicates that mobile phones have a peak power level between 0.1 and 2 watts.
“Electromagnetic fields and public health: mobile phones”, FactSheet N 193, June 2011
( http://www.who.int/mediacentre/factsheets/fs193/en/ ).
16
Panasonic specifies the power output of its DECT 6.0 cordless telephone Model KXTG1061 as 115 milliwatts for the handset and
another115 milliwatts for the base station for a total capacity of 230 milliwatts.
( http://service.us.panasonic.com/OPERMANPDF/KXTG1061-MUL.PDF ). Other cordless models may use higher power levels.
Additional references are being sought for clarification.
6
this: AThe fact that there are other sources of microwave radiation in your environment is exactly why you
don=t want any more, as that only exacerbates the health risks.@

If you would like to learn more about the possible adverse health effects of electromagnetic fields, including
microwaves from Smart Meters, view the 45-minute on-line video made by Dietrich Klinghardt, M.D., Ph.D., as
posted on the web site of Joseph Mercola, D.O. Dr. Klinghardt is one of the world=s leading experts on the
impact of the environment on human health. In particular, he has done extensive work with autistic
children. That video appears part way down the following web page, under the heading ASmart Meters and
Electromagnetic Radiation - the Health Crisis of Our Time@:

http://articles.mercola.com/sites/articles/archive/2012/12/05/smart-utility-meters.aspx

Concern No. 2: SECURITY

Smart Meters decrease both your personal security and the cyber security of your supply of electrical power.

Personal Security: The Smart Meter broadcasts, to anyone who can receive and decode the signal, a
power profile that will be sufficient to determine when you are home, when you are on vacation, when
you go to bed at night, and when you rise in the morning, thus raising personal security concerns.

Cyber Security: Because the wireless Smart Meters are, indeed, wireless, they are potentially
vulnerable to Ahacking@ by those who wish to do mischief, or worse. In fact, a wireless Smart Meter
network, similar to that in our community, has already been hacked in order to demonstrate its
vulnerability.17 The risk from such hacking is of special concern because a wireless Smart Meter can
shut off your electric power, may be able to shut off individual Smart Appliances in your home, and, of
course, does determine your reported electricity consumption for billing purposes. By comparison,
the traditional analog mechanical power meters, that have served us well for years, are inherently
resistance to such hacking, have no shut-off capability, and cannot be tampered with remotely.

If you would like to know more about the impact of Smart Meters on the security of the electrical
power grid, view the on-line video of James Woolsey, former Director of the CIA, posted on the same
web site above, just above the heading AGetting Smarter about the Smart Grid@. He calls the
supposed Asmart grid@ (of which Smart Meters are a part) the Astupid grid@ because of its vulnerability
to cyber attack.

http://articles.mercola.com/sites/articles/archive/2012/12/05/smart-utility-meters.aspx

Concern No. 3: PRIVACY

The Smart Meters feed data to the electric power company everyday about your usage of electric power and
about your ownership and use of Smart Appliances. These data, which are sometimes called your Aelectric
power profile@, may be collected and processed by third-party companies on behalf of the electric power
companies. There is no legal protection in place to prevent uses of that information which you may not like,
including the sale of that information to other parties. And there are an endless number of possible
“customers” for that information. For example, sellers of Smart Appliances may want your data to
determine which Smart Appliances you own, and whether they should target you with advertising for new

17
The hacking report appears at the following URL on the web site of StopSmartMeters.org:
( http://stopsmartmeters.org/2013/01/19/full-speed-toward-an-iceberg-silver-spring-hacked ).
7
Smart Appliances. Data mining companies may want your data for targeted advertising and a host of other
applications. And law enforcement authorities and security agencies may want your data for surveillance
purposes.

Given that the electronic modules in Smart Meters can be reprogrammed remotely, it is impossible to know,
at this time, what additional uses will be found for Smart Meters in the future B uses that can be implemented
without your knowledge or your approval.

Thus, once a Smart Meter has been mounted on your home and begins sending microwave signals into your
home, and receiving microwave signals from inside your home, it will be difficult to determine what tasks this
new type of surveillance device is actually performing.

If you would like to know more about the privacy issue with Smart Meters, consider the following on-line
video made my Jerry Day. I do not know much about him, but his message seems correct.18

http://www.youtube.com/watch?v=8JNFr_j6kdI&list=UUklG6ilxW_PeYeDSpKSRGZQ

Concern No. 4: FIRE SAFETY

Smart Meters have been implicated in hundreds of house fires, for reasons that are not yet publicly
understood. The Maryland Public Service Commission was sufficiently concerned about the fire hazard that
it held a special hearing on this topic in August 2012. I have not yet heard a report of its findings.

Our local fire department, on Montgomery Village Avenue, indicated in early January 2013, that, as of that
time, it had not yet seen a Smart Meter fire in Montgomery Village. But the fire department advised that if
an electrical fire of this type should occur, the fire department cannot fight that fire until the electrical power
is first turned off by PEPCO. So, if a Smart Meter fire does start, homeowners and their neighbors, after
assuring their own personal safety, should call BOTH the fire department and PEPCO, and then await PEPCO=s
arrival.

If you would like to know more about the fire-safety issue, enter ASmart Meter Fires@ into your Internet search
engine. You will find many responses, some of which contain videos, like the one below, of Smart Meter
fires:
http://www.youtube.com/watch?v=Ah3nNo89-NU

Concern No. 5: HIDDEN COSTS AND DOUBTFUL BENEFITS FOR THE CONSUMER

PEPCO is not overtly charging for Smart Meters, in the form of an explicit charge on your electric-power bill.
But, clearly there will be a cost for the enormous number of Smart Meters involved, for their installation, for
the creation of the extensive wireless microwave mesh network that supports these meters, for the
maintenance of all of this microwave equipment, and for the processing of the volumes of data collected by
the Smart Meters. I don=t have documented figures on the costs, but I have seen an estimate of $1 billion for
Maryland alone. The U.S. Government is providing part of the funding through the stimulus bill of 2009.
You can guess who is going to repay that cost, and the rest of the costs, in the form of taxes and rate increases
for electricity. In fact, PEPCO has already filed, with the Maryland Public Service Commission, for a rate
increase totaling $60.8 million, on November 30, 2012. For the typical residential customer, PEPCO indicates
that this increase will be $7.13 per month per 1000 kWh of electrical energy consumed, which amounts to an

18
Jerry Day’s web sites: ( http://www.jerryday.com ) and ( http://www.freedomtaker.com ).
8
increase of 4.98 percent.19 Of course, we have to expect some increases in the cost of electricity over time.
But, in this case, we can wonder if the costs associated with Smart Meters are a major factor in this increase.

Further, the financial benefits of Smart Meters to customers are in doubt. Several State Attorneys General
have objected:

A study by the Attorney General of Connecticut found that the claimed financial benefits of Smart
Meters do NOT justify the costs.20

An assessment by the Attorney General of Illinois found that Smart Meters were more about profits for
the utilities than about savings for their customers.21

The Attorney General of Michigan cited the lack of evidence that Smart Meters “will actually produce a
net economic benefit to customers.”22

Further, many Maryland customers are concerned that PEPCO is spending an enormous amount of money on
Smart Meters that would be better spent addressing the real problem of concern to PEPCO=s customers: the
reliability of the PEPCO power system. Improved reliability might be better achieved by other changes, such
as burying power lines that are vulnerable to damaging storms, and improving the control and monitoring
systems at key junctions on the electric power grid. It is doubtful that collecting detailed data on power
usage in every individual home, every day of the year, through wireless Smart Meters, is as important to
improving reliability.

Concern No. 6: PROPERTY VALUES

It is early to predict the impact of Smart Meters on entire communities, like Montgomery Village, but perhaps
not entirely too early. We have only to look at communities in which Smart Meters were installed much
earlier than they were here. California provides a striking example. Smart Meters were installed in parts of
that state beginning several years ago. Since then, 57 counties, cities, and towns in California have opposed
mandatory installation of Smart Meters in their jurisdictions. And 15 of the 57 have prohibited them
altogether.23 So once residents and governments have had a chance to consider the implications of Smart
Meters for their communities, they have often turned against them. This kind of concern is reflected
nationwide by the emergence of many groups opposed to Smart Meters in many states.24

19
To find the details on PEPCO’s requested rate increase, enter “9311” (without the quotes) into the box “Case Search” on this PSC
web page: ( http://webapp.psc.state.md.us/Intranet/home.cfm ). Select the first item on the resulting list by clicking on “See
more.” Then see pages 3 and 5 in Volume I of II, in the file VolIofII.pdf. See also page 10 in Volume II of II, in the file VolIofII.pdf.
Both volumes are about 400 pages long, so downloading them will take time. The rate increase described here applies to what
PEPCO calls “a typical residential Standard Offer Service (SOS) customer”.
20
The statement by the Connecticut Attorney General, George Jepsen, can be found on the Internet in this document:
( http://www.ct.gov/ag/lib/ag/press_releases/2011/020811clpmeters.pdf ).
21
The statement by the Illinois Attorney General, Lisa Madigan, can be found on the Internet here:
( http://www.lisamadigan.org/Newsroom/lisainthenews/item/2011-06-lisa-madigan-opinion-editorial-comed-experiment-too ).
22
The statement by the Michigan Attorney General, Bill Shuette, can be found on the Internet here:
( http://www.annarbor.com/DTE-SMART-METERS_ATTORNEY-GENERAL-OPINION.pdf ).
23
See article “CA Local Governments on Board”.
( http://stopsmartmeters.org/how-you-can-stop-smart-meters/sample-letter-to-local-government/ca-local-governments-on-board )
24
( http://www.scribd.com/doc/100365955/Actions-Opposing-Smart-Meters-Across-the-United-States ) and
( http://takebackyourpower.net/worldwide-directory/usa )
9
So it does not require too much insight to realize that more individuals and families, looking for a home, might
prefer to live in a community that has already eliminated Smart Meters. This inclination may ultimately
depress property values, and the associated tax base, in communities that decide to tolerate Smart Meters.
This inclination may also boost property values, and the associated tax base, in communities that eliminate
Smart Meters. Looking at this issue another way, I have yet to hear of a single person who finds the
presence of Smart Meters a positive factor in determining where to live.

For Further Information about the Concerns

If you would like to know more about the concerns related to Smart Meters, visit the web site below, or the
many other web sites on the Internet. The web site below is that of Maryland Smart Meter Awareness.
There you will find extensive information about Smart Meters. The brochure of this organization is included
in this package as Attachment No. 7.

http://marylandsmartmeterawareness.org

This organization is a non-profit, public-spirited group of Maryland volunteers with more than 500 members.
They represent many fields, including doctors, scientists, engineers, computer experts, lawyers, and
concerned parents broadly. They are not anti-technology; in fact, many of them have spent their careers
developing advanced technology. Rather, they recognize an unwise use of technology when they see it.
They are working hard to educate Marylanders about the serious consequences of Smart Meters.

You may also wish to monitor the web site of the Maryland Public Service Commission (PSC) for emerging
information. The Maryland PSC regulates the electric power utilities for the Maryland State Government.
All postings can be found here:

http://webapp.psc.state.md.us/Intranet/Casenum/CaseAction_new.cfm?RequestTimeout=500?

You may have to wait a minute or two for this web site to come up. Then, to see all actions of relevance to
PEPCO customers, enter 9207 in the box entitled ACase Search@. When Case Number 9207 comes up, you
may wish to see Item 203. Click there on ASee more.@ to read the temporary Order 84926 that PSC issued to
permit Maryland residents to OPT OUT of the installation of Smart Meters and thus to stay with the traditional
analog mechanical meters.

If you search the Internet for information on Smart Meters more generally, you will find that there are many
organizations, around the nation and in other countries, too, that have been formed to resist Smart Meters,
and why those organizations are concerned. A good set of keywords on which to search is “Smart Meter
Opposition”.

How Can You OPT OUT of Having a Wireless Smart Meter?

So many Maryland residents have objected to the installation of the new wireless Smart Meters that the
Maryland Public Service Commission (PSC) has responded. In May 2012, the PSC issued Order 84926, giving
Maryland customers the right to OPT OUT of the installation of Smart Meters while the PSC reviews the
situation. This right extends both to customers who do not yet have a Smart Meter and to those who already
have a Smart Meter and would like it replaced. At the moment, this order is temporary, so those wishing to
take advantage of it will want to do so promptly. The PSC cannot tell us, at this time, whether, or when, this

10
order will be revoked or extended. If this order is revoked, Smart Meters could be reimposed on those who
have OPTED OUT, whether before or after the installation of a Smart Meter.

Many of your neighbors have already OPTED OUT, to protect themselves and their neighbors. Some of your
neighbors OPTED OUT before the Smart Meters were installed and thus avoided the installation of Smart
Meters altogether. Other neighbors are OPTING OUT now, after the installation of the Smart Meters. To
date, the requests from our neighbors, to OPT OUT after installation, have been honored by PEPCO without
incident. The Smart meters have been removed by PEPCO in 4 to 21 days after the requests were received.
You may OPT OUT, too, if you wish to do so.

If you decide to OPT OUT, you must notify PEPCO in writing.

PEPCO Smart Grid Deferral

Mail Stop EP7642
701 9th Street NW
Washington, DC 20068

You may write your own letter, following the guidance on the web site MarylandSmartMeterAwareness.org.
Or you may use a form letter, designed according to the guidance from MarylandSmartMeterAwareness.org
and from the Maryland Public Service Commission. A copy of that form letter is provided as Attachment
No. 5. Note that the inclusion of your PEPCO Account Number, from your latest PEPCO bill, is vital. To date,
PEPCO has responded to most OPT OUT letters from your neighbors with return letters of its own,
documenting that their request to OPT OUT has been received. Keep that return letter on hand, as proof
that you have notified PEPCO. When you send your letter to PEPCO, post a sign on your Smart Meter that
will remain there until PEPCO=s contractor comes to make the replacement. A copy of the sign, prepared for
double-sided printing, is desired, is provided as Attachment No. 6.

When you send your letter to PEPCO to OPT OUT, you may wish to keep a copy, and to send your letter by
ACertified U.S. Mail, with a Return Receipt Requested@. Then, if PEPCO fails to send you a return letter
documenting your request to OPT OUT, you can use a copy of the letter you sent to PEPCO, plus the Return
Receipt, as evidence that you have properly notified PEPCO that you have OPTED OUT.

If you already have an installed Smart Meter, the Maryland PSC tells me that there are two different actions
that PEPCO can take to comply with your request to OPT OUT:

(1) Remove the wireless Smart Meter and replace it with a traditional analog mechanical meter.
OR (2) Remove the wireless Smart Meter and replace it with another Smart Meter that has its transmitter
turned off.

However, we have observed a third response by PEPCO, that was not explicitly described to me by the PSC,
but that likely complies with the PSC=s order:

(3) Remove the wireless Smart Meter and replace it with a digital meter that has no wireless
transmission capability.

11
 The first meter of this type that we have seen in our community
is the Alpha Plus, A1T+ variation, made by Elster, shown here.25
This A1T+ variation does support Atime-of-use@ metering
capabilities; that is, it can be set to charge different rates for
electricity used at different times of day. However, this meter
does not have Aload profile recording@ capabilities so it probably
cannot conduct surveillance. This meter offers several
communications options. But all of them, as far as I can tell,
are wired methods, such as a modem for telephone dial in. So
this meter, like (1) above, appears to eliminate any possibility of
microwave radiation exposure.

In my view, the relative desirability of the three options above is this:

Option (1) above is the most desirable approach and, thus, it is the best one to specify in the OPT OUT
letter to PEPCO, if only because a visual inspection of your meter will be sufficient to determine if
PEPCO has complied. Also, specifying a ATraditional Analog Mechanical Meter with no wireless
transmission capability@ will help assure that you are not given a traditional meter that has been
modified by the addition of wireless transmission capability, as some have been.

Option (3) is a close second, because it fully protects the residents from microwave radiation exposure,
and, presumably, from surveillance.

Option (2) is a distant third because a Smart Meter with its transmitter turned off may look no
different from a Smart Meter with its transmitter turned on, so you may not know if the transmitter is
truly off, and permanently so. Also, it is unclear to me at this time whether PEPCO can turn the
transmitter on and off, remotely, just by sending a microwave signal to the receiver in the Smart
Meter. Even if the transmitter is permanently off, you may still face some of the other concerns
about Smart Meters, as described above. For example, if the receiver is still operational, then PEPCO
may still have the capability to turn your power off remotely, and it may still be possible for your Smart
Meter to be hacked.

What Should You Do on the Day PEPCO=s Contractor Comes to Replace Your
Smart Meter?
The attached form letter asks PEPCO to contact you to set a date and a time for the replacement of your
Smart Meter. The principal purpose of this request is to give you, or a family member, the option to be
present when your Smart Meter is replaced, which is highly recommended.

If you can be present, you can talk with the PEPCO contractor before the replacement begins, to be certain
that the replacement meter will be a ATraditional Analog Mechanical Meter with no wireless transmission
capability@ as specified in your letter to PEPCO and as stated on the sign you have posted on your Smart
Meter. The sign will be especially important if you are not able to be home at the time of the replacement.

25
The Alpha Plus family of meters is described here: ( http://www.elstermetering.com/en/915.html ). The variations available for
this meter, like the A1T+, are described here:
( http://www.tikaenergy.com/Elster_info/Elster_ALPHA_Plus_Meter_Variations_and_Specifications_E.pdf ).
12
Finally, before the PEPCO contractor makes the replacement, turn off all appliances in your home, and, if you
are able to do so, all circuit breakers in your electrical load (service) panel, where the electrical power enters
your home. This will assure that no electrical current is flowing through the power meters during the
replacement. This procedure eliminates any possibility of an electrical flash over that could damage the
electrical contacts on the power meter, or the electrical contacts on the power box in which your meter is
installed. This procedure is also safer for the PEPCO contractor. Unfortunately, the PEPCO contractors have
been installing the Smart Meters Ahot@, that is, without turning off the power drawn by the home first. After
the PEPCO contractor tells you that he or she has completed the exchange of your Smart Meter for a
ATraditional Analog Mechanical Meter without wireless transmission capability@, you can turn your circuit
breakers back on.

What Can You Do if PEPCO Fails to Respond Promptly to Your OPT OUT Request?
To date, PEPCO has complied promptly with our neighbors= written requests for removal of their Smart
Meters. However, if PEPCO should fail to respond promptly to your written request for removal, notify the
Maryland PSC by letter, so that the PSC can enforce your request. Here is the address for this purpose:

Odogwn Obi Linton, Director

Office of External Relations
Public Service Commission of Maryland
William Donald Schaeffer Tower
6 St. Paul St., 16th Floor
Baltimore, MD 21202-6806

Is There a Possible Downside To Opting Out?

Yes, in this sense: PEPCO wants to charge a fee to Maryland residents who OPT OUT, perhaps even a
monthly fee, even though the Maryland PSC currently permits OPTING OUT. PEPCO=s OPT-OUT customers
view such a fee dimly. To them, this is a fee for the privilege of not being irradiated by PEPCO=s Smart
Meters. Fortunately, at this time, there is no fee for OPTING OUT. Also a bill, HB1038, has been introduced
in the Maryland House of Delegates, by Delegate Glen Glass, with nineteen co-sponsors. If this bill becomes
law, it will prevent any fee from being charged for OPTING OUT, ever. You may read that bill here:

http://legiscan.com/gaits/search?state=MD&bill=HB1038

This bill has many provisions, including the following. These provisions are important both for customers
who OPT OUT and for customers who don=t OPT OUT:

(1) makes your right to OPT OUT permanent, but does not require anyone to OPT OUT
(2) prevents the electric power utilities from charging their customers any fee for OPTING OUT
(3) bars the electric utilities from selling your personal data, collected by your Smart Meter, to others.

13
What Can You Do to Make the Current Temporary OPT OUT Permanent, and
With No Fee?
There are two parts of the Maryland State Government that have the power to make the current temporary
OPT OUT permanent: (1) the Maryland Public Service Commission, and (2) the Maryland General Assembly
(which is the state=s legislature). The first can act sooner than the second, but the second rules in the end.

Here is what you can do to help, if you would like to keep the right to OPT OUT:

(1) Send an e-mail message to the members of the Economic Matters Committee of the Maryland
House of Delegates, urging their support for HB1038. As noted above, this bill will make the right
to OPT OUT permanent. But this bill must be approved by this committee in order to be sent on
to the full House of Delegates for a vote. You can find an Internet form for sending such a
message here:

http://actionmail.ksconline.net/md-house-econ-committee.html

The Economic Matters Committee held a meeting to hear testimony from the public, the electric
power companies, and the Maryland Public Service Commission about HB1038 on Thursday,
March 14, 2013. Marylanders from across the State completely filled the hearing room, and
testified in row after row. Both verbal and written testimony from medical doctors and scientists
was included. All those testifying received a good hearing in proceedings that lasted for two
hours. After the hearing, the Committee decided to study HB1038 further over the summer.

You may view this hearing in its entirety on the Internet on the web site below. The part of the
hearing addressing HB1038 begins at time 00:05:11 and ends at time 02:07:00. When you first
click on the web site below, a message will alert you that you need to down load the Microsoft
Silverlight viewer to see the video, and will give you a button to click on to install it. Thereafter,
the video will play.

http://mgahouse.maryland.gov/house/play/1caf8e854c2f430ca06e88e79fbf8ffa/?catalo
g/03e481c7-8a42-4438-a7da-93ff74bdaa4c&playfrom=311873

(2) If you have already OPTED OUT, send a letter to the Maryland Public Service Commission (PSC),
indicating that you have OPTED OUT of the PEPCO Smart Meter installation, and why. The
Maryland PSC has the authority to extend the OPT OUT privilege, but needs to know the level of
interest of Marylanders. Let the PSC know that you would like to see its TEMPORARY OPT OUT
order made permanent, and with no OPT-OUT fee. Otherwise, the PSC may later terminate its
temporary order and force you to accept a wireless Smart Meter. Here is the address for such a
letter:

Public Service Commission (re: Smart Meter Opt Out)

Attn: David J. Collins, Executive Secretary
William Donald Schaefer Tower
6 St. Paul Street, 16th Floor
Baltimore, MD 21202-6806

14
(3) Send an e-mail message to Maryland State Delegate Glen Glass, in support of the bill HB1038. He
is the author of HB1038, which, as noted above, now has nineteen co-sponsors. Delegate Glass
represents State District 34a, which includes Cecil County and Harford County.

State Delegate Glen Glass: [email protected]

(4) Send an e-mail message to your Maryland State Senator and to your three Maryland State
Delegates, with your views. Encourage these representatives to support the new Maryland House
of Delegates bill, HB1038.

Here are the e-mail addresses applicable to Montgomery Village residents in Maryland State
District 14 (North Village, East Village, and Eastgate communities):

State Senator Karen Montgomery: [email protected]

State Delegate Anne Kaiser: [email protected]
State Delegate Eric Luedtke: [email protected]
State Delegate Craig Zucker: [email protected]

Here are the e-mail addresses applicable to Montgomery Village residents in Maryland State
District 39 (all other communities in Montgomery Village):

State Senator Nancy J. King: [email protected]

State Delegate Charles Barkley: [email protected]
State Delegate Kirill Reznik: [email protected]
State Delegate A. Shane Robinson: [email protected]

(5) Send an e-mail message to our representative in the U.S. House of Representatives, John Delaney,
seeking his support for House bill H.R. 6358. You can reach him through his contact form on his
web site:

https://delaney.house.gov/contact/email-me

This bill will support research toward new exposure limits to protect the public better from
harmful levels of electromagnetic radiation, including the microwave radiation from Smart
Meters. You can read a summary of the bill on the site of Maryland Smart Meter Awareness:

http://marylandsmartmeterawareness.org/smart-meter-news/ask-your-congressional-r
ep-to-co-sponsor-h-r-6358

You can read the entire bill on the web site of the U.S. Congress:

http://thomas.loc.gov/home/gpoxmlc112/h6358_ih.xml

If you scan through the bill, you will find a list of specific health problems, arising from exposure to
electromagnetic radiation, that need further research.

15
 (6) Support Maryland Smart Meter Awareness (MSMA)

MSMA is non-profit advocacy group, composed of public-spirited Maryland volunteers from many
fields. These individuals are working hard to raise awareness about wireless Smart Meters and
to assure that your right to OPT OUT is preserved in the future. MSMA is interacting with
Maryland State officials, including the Maryland General Assembly and the Maryland Public
Service Commission. You may wish to log in, periodically, to the organization=s web site to see
what is happening. And you may wish to join the organization and to contribute to its support,
as I, too, have done. The brochure of Maryland Smart Meter Awareness is provided as
Attachment No. 7.

http://marylandsmartmeterawareness.org

Closing
Since the public has not been well informed about the implications of wireless Smart Meters and about the
right to OPT OUT, we must rely on each other to spread the word, so that those who wish to OPT OUT may do
so. Feel free to speak with your neighbors, family members, and friends about this topic. We are all in this
together, for at least two reasons:

(1) We all experience microwave radiation, not only from our own Smart Meter, but also from the
Smart Meters of our neighbors, especially our nearest neighbors because they are closest. So
Smart Meters are truly a community issue, not just an individual issue.

(2) We need our neighbors= help to write to the Maryland House of Delegates and to the Maryland
Public Service Commission in support of a permanent right to OPT OUT, as described above. We
have a chance to make our democracy work for us, but only if we participate.

In the meantime, we Marylanders can be grateful that we have a right to OPT OUT, even if it is currently
temporary. That right makes OPTING OUT routine for us. Unfortunately, some states offer no OPT-OUT
rights to their residents. Our friends in DC and Pennsylvania envy us, because they have no right to OPT
OUT; and they are struggling hard to get that right. Our friends in Virginia have no state-wide OPT-OUT
rights. But those residents who are customers of Dominion Virginia Power have just received a limited form
of an OPT OUT that addresses several of the major concerns about Smart Meters.26

Attachments
Several attachments, referred to in the text above, follow.

26
Dominion Virginia Power announced, on April 22, 2013, that its customers may elect a Smart Meter with “both the two way
communications and data storage features disabled; the only recording features retained are the minimum needed for monthly
billing.” ( https://www.dom.com/about/conservation/pdf/meter-option-requirements.pdf ) Dominion Virginia Power, at
1-866-566-6436, indicated the following (paraphrased): When this option is elected by a customer, Dominion Virginia Power will
replace the wireless Smart Meter with a different Smart Meter with the named features disabled. Restoration of the disabled
features would require replacement with a different meter. This offer from Dominion Virginia Power is voluntary and was not
mandated by the Virginia General Assembly or by the Virginia State Corporation Commission which regulates the electric power
companies.
16
 American Academy of Environmental
Medicine
6505 E Central • Ste 296 • Wichita, KS 67206
Tel: (316) 684-5500 • Fax: (316) 684-5709
www.aaemonline.org

Executive Committee

President Press Advisory

A.L. Barrier, M.D., FAAO-HNS April 12, 2012
One Hospital Drive Contact Information:
Columbia, MO 65212 Dr. Amy L. Dean, D.O.
President‐Elect
President-Elect American Academy of Environmental Medicine
Amy Dean, D.O.
(734)213‐4901
1955 Pauline Blvd Ste 100D
Ann Arbor, MI 48103 [email protected]
@dramydean
Secretary
Charles L. Crist, M.D.
3009 Falling Leaf Ctr, Ste 1 The American Academy of Environmental Medicine Calls for
Columbia, MO 65201 Immediate Caution regarding Smart Meter Installation

Treasurer Wichita, KS‐ The American Academy of Environmental Medicine today released its position
James W. Willoughby, II, D.O. paper on electromagnetic field (EMF) and radiofrequency (RF) health effects calling for
24 Main St. immediate caution regarding smart meter installations. Citing several peer‐reviewed
Liberty, MO 64068 scientific studies, the AAEM concludes that “significant harmful biological effects occur
from non‐thermal RF exposure” showing causality. The AAEM also expresses concern
Immediate Past President
Robin Bernhoft, M.D., FAAEM regarding significant, but poorly understood quantum field effects of EMF and RF fields on
human health.
Advisor
Gary R. Oberg, M.D.,FAAEM “More independent research is needed to assess the safety of ‘Smart Meter’ technology,”
said Dr. Amy Dean, board certified internist and President‐Elect of the AAEM. “Patients are
reporting to physicians the development of symptoms and adverse health effects after
Board of Directors ‘Smart Meters’ are installed on their homes. Immediate action is necessary to protect the
Craig Bass, M.D. public’s health.”
Amy Dean, D.O.
Stephen Genuis, M.D., FAAEM Dr. William J. Rea, past president of AAEM says, “Technological advances must be assessed
Martha Grout, M.D., MD(H) for harmful effects in order to protect society from the ravages of end‐stage disease like
Janette Hope, M.D.
cancer, heart disease, brain dysfunction, respiratory distress, and fibromyalgia. EMF and
W. Alan Ingram, M.D.
Derek Lang, D.O. wireless technology are the latest innovations to challenge the physician whose goal is to
Glenn A. Toth, M.D. help patients and prevent disease.” Rea, a thoracic and cardiovascular surgeon and
Ty Vincent, M.D. environmental physician adds, “A more thorough review of technological options to
achieve society’s worthwhile communications objectives must be conducted to protect
Continuing Medical Education human health.”
Chairman
James W. Willoughby, II, D.O. The AAEM calls for:
24 Main St.
• Immediate caution regarding “Smart Meter” installation due to potentially harmful
Liberty, MO 64068
RF exposure
Executive Director • Accommodation for health considerations regarding EMF and RF exposure,
De Rodgers Fox
including exposure to wireless “Smart Meter” technology
• Independent studies to further understand health effects from EMF and RF
exposure
 Press Advisory 12.04.12
Page 2

• Use of safer technology, including for “Smart Meters”, such as hard‐wiring, fiber optics or other
non‐harmful methods of data transmission
• Independent studies to further understand the health effects from EMF and RF exposures
• Recognition that electromagnetic hypersensitivity is a growing problem worldwide
• Consideration and independent research regarding the quantum effects of EMF and RF on
human health
• Understanding and control of this electrical environmental bombardment for the protection of
society

The AAEM’s position paper on electromagnetic and radiofrequency fields can be found at:
http://aaemonline.org/emf_rf_position.html
AAEM is an international association of physicians and other professionals dedicated to addressing the
clinical aspects of environmental health. More information is available at www.aaemonline.org.

‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
About AAEM: The American Academy of Environmental Medicine was founded in 1965, and is an
international association of physicians and other professionals interested in the clinical aspects of humans
and their environment. The Academy is interested in expanding the knowledge of interactions between
human individuals and their environment, as these may be demonstrated to be reflected in their total
health. The AAEM provides research and education in the recognition, treatment and prevention of
illnesses induced by exposures to biological and chemical agents encountered in air, food and water.
###
 American Academy of Environmental Medicine

Electromagnetic and Radiofrequency Fields Effect on Human Health

For over 50 years, the American Academy of Environmental Medicine (AAEM) has been studying
and treating the effects of the environment on human health. In the last 20 years, our physicians began
seeing patients who reported that electric power lines, televisions and other electrical devices caused a
wide variety of symptoms. By the mid 1990’s, it became clear that patients were adversely affected by
electromagnetic fields and becoming more electrically sensitive. In the last five years with the advent of
wireless devices, there has been a massive increase in radiofrequency (RF) exposure from wireless
devices as well as reports of hypersensitivity and diseases related to electromagnetic field and RF
exposure. Multiple studies correlate RF exposure with diseases such as cancer, neurological disease,
reproductive disorders, immune dysfunction, and electromagnetic hypersensitivity.

The electromagnetic wave spectrum is divided into ionizing radiation such as ultraviolet and X‐
rays and non‐ionizing radiation such as ultrasound and radiofrequency (RF), which includes WiFi, cell
phones, and Smart Meter wireless communication. It has long been recognized that ionizing radiation
can have a negative impact on health. However, the effects of non‐ionizing radiation on human health
recently have been seen. Discussions and research of non‐ionizing radiation effects centers around
thermal and non‐thermal effects. According to the FCC and other regulatory agencies, only thermal
effects are relevant regarding health implications and consequently, exposure limits are based on
thermal effects only.1

While it was practical to regulate thermal bioeffects, it was also stated that non‐thermal effects
are not well understood and no conclusive scientific evidence points to non‐thermal based negative
health effects.1 Further arguments are made with respect to RF exposure from WiFi, cell towers and
smart meters that due to distance, exposure to these wavelengths are negligible.2 However, many in
vitro, in vivo and epidemiological studies demonstrate that significant harmful biological effects occur
from non‐thermal RF exposure and satisfy Hill’s criteria of causality.3 Genetic damage, reproductive
defects, cancer, neurological degeneration and nervous system dysfunction, immune system

1
dysfunction, cognitive effects, protein and peptide damage, kidney damage, and developmental effects
have all been reported in the peer‐reviewed scientific literature.

Genotoxic effects from RF exposure, including studies of non‐thermal levels of exposure,

consistently and specifically show chromosomal instability, altered gene expression, gene mutations,
DNA fragmentation and DNA structural breaks.4‐11 A statistically significant dose response effect was
demonstrated by Maschevich et al. , who reported a linear increase in aneuploidy as a function of the
Specific Absorption Rate(SAR) of RF exposure.11 Genotoxic effects are documented to occur in neurons,
blood lymphocytes, sperm, red blood cells, epithelial cells, hematopoietic tissue, lung cells and bone
marrow. Adverse developmental effects due to non‐thermal RF exposure have been shown with
decreased litter size in mice from RF exposure well below safety standards.12 The World Health
Organization has classified RF emissions as a group 2 B carcinogen.13 Cellular telephone use in rural
areas was also shown to be associated with an increased risk for malignant brain tumors. 14

The fact that RF exposure causes neurological damage has been documented repeatedly.
Increased blood‐brain barrier permeability and oxidative damage, which are associated with brain
cancer and neurodegenerative diseases, have been found.4,7,15‐17 Nittby et al. demonstrated a
statistically significant dose‐response effect between non‐thermal RF exposure and occurrence of
albumin leak across the blood‐brain barrier.15 Changes associated with degenerative neurological
diseases such as Alzheimer’s, Parkinson’s and Amyotrophic Lateral Sclerosis (ALS) have been
reported.4,10 Other neurological and cognitive disorders such as headaches, dizziness, tremors,
decreased memory and attention, autonomic nervous system dysfunction, decreased reaction times,
sleep disturbances and visual disruption have been reported to be statistically significant in multiple
epidemiological studies with RF exposure occurring non‐locally.18‐21

Nephrotoxic effects from RF exposure also have been reported. A dose response effect
was observed by Ingole and Ghosh in which RF exposure resulted in mild to extensive degenerative
changes in chick embryo kidneys based on duration of RF exposure.24 RF emissions have also been
shown to cause isomeric changes in amino acids that can result in nephrotoxicity as well as
hepatotoxicity.25

Electromagnetic field (EMF) hypersensitivity has been documented in controlled and double
blind studies with exposure to various EMF frequencies. Rea et al. demonstrated that under double
blind placebo controlled conditions, 100% of subjects showed reproducible reactions to that frequency

2
to which they were most sensitive.22 Pulsed electromagnetic frequencies were shown to consistently
provoke neurological symptoms in a blinded subject while exposure to continuous frequencies did not.23

Although these studies clearly show causality and disprove the claim that health effects from
RF exposure are uncertain, there is another mechanism that proves electromagnetic frequencies,
including radiofrequencies, can negatively impact human health. Government agencies and industry set
safety standards based on the narrow scope of Newtonian or “classical” physics reasoning that the
effects of atoms and molecules are confined in space and time. This model supports the theory that a
mechanical force acts on a physical object and thus, long‐range exposure to EMF and RF cannot have an
impact on health if no significant heating occurs. However, this is an incomplete model. A quantum
physics model is necessary to fully understand and appreciate how and why EMF and RF fields are
harmful to humans.26,27 In quantum physics and quantum field theory, matter can behave as a particle
or as a wave with wave‐like properties. Matter and electromagnetic fields encompass quantum fields
that fluctuate in space and time. These interactions can have long‐range effects which cannot be
shielded, are non‐linear and by their quantum nature have uncertainty. Living systems, including the
human body, interact with the magnetic vector potential component of an electromagnetic field such as
the field near a toroidal coil.26,28,29 The magnetic vector potential is the coupling pathway between
biological systems and electromagnetic fields.26,27 Once a patient’s specific threshold of intensity has
been exceeded, it is the frequency which triggers the patient’s reactions.

Long range EMF or RF forces can act over large distances setting a biological system oscillating
in phase with the frequency of the electromagnetic field so it adapts with consequences to other body
systems. This also may produce an electromagnetic frequency imprint into the living system that can be
long lasting.26,27,30 Research using objective instrumentation has shown that even passive resonant
circuits can imprint a frequency into water and biological systems.31 These quantum electrodynamic
effects do exist and may explain the adverse health effects seen with EMF and RF exposure. These EMF
and RF quantum field effects have not been adequately studied and are not fully understood regarding
human health.

Because of the well documented studies showing adverse effects on health and the not fully
understood quantum field effect, AAEM calls for exercising precaution with regard to EMF, RF and
general frequency exposure. In an era when all society relies on the benefits of electronics, we must
find ideas and technologies that do not disturb bodily function. It is clear that the human body uses
electricity from the chemical bond to the nerve impulse and obviously this orderly sequence can be

3
disturbed by an individual‐specific electromagnetic frequency environment. Neighbors and whole
communities are already exercising precaution, demanding abstention from wireless in their homes and
businesses.

Furthermore, the AAEM asks for:

• An immediate caution on Smart Meter installation due to potentially harmful RF exposure.

• Accommodation for health considerations regarding EMF and RF exposure, including exposure
to wireless Smart Meter technology.
• Independent studies to further understand the health effects from EMF and RF exposure.
• Recognition that electromagnetic hypersensitivity is a growing problem worldwide.
• Understanding and control of this electrical environmental bombardment for the protection of
society.
• Consideration and independent research regarding the quantum effects of EMF and RF on
human health.
• Use of safer technology, including for Smart Meters, such as hard‐wiring, fiber optics or other
non‐harmful methods of data transmission.

Submitted by: Amy L. Dean, DO, William J. Rea, MD, Cyril W. Smith, PhD, Alvis L. Barrier, MD

4
Bibliography: Electromagnetic and Radiofrequency Fields Effect on Human Health

1. California Council on Science and Technology. (Internet). (2011). Health Impacts of

Radiofrequency Exposure from Smart Meters. Available from:
http://www.ccst.us/publications/2011/2011smartA.pdf
2. Electric Power Research Institute. (Internet). (2011). Radio‐Frequency Exposure Levels from
Smart Meters: A Case Study of One Model. Available from:
https://www.nvenergy.com/NVEnergize/documents/EPRI_1022270_caseStudy.pdf
3. Hill, AB. The Environment and Disease: Association or Causation? Proceedings of the Royal
Society of Medicine. 1965; 58: 295‐300.
4. Xu S, Zhou Z, Zhang L, et al. Exposure to 1800 MHZ radiofrequency radiation induces oxidative
damage to mitochondrial DNA in primary cultured neurons. Brain Research. 2010; 1311: 189‐
196.
5. Phillips JL, Singh NP, Lai H. Electromagnetic fields and DNA damage. Pathophysiology. 2009; 16:
79‐88.
6. Ruediger HW. Genotoxic effects of radiofrequency electromagnetic fields. Pathophysiology.
2009; 16(2): 89‐102.
7. Zhao T, Zou S, Knapp P. Exposure to cell phone radiation up‐regulates apoptosis genes in
primary cultures of neurons and astrocytes. Neurosci Lett. 2007; 412(1): 34‐38.
8. Lee S, Johnson D, Dunbar K. 2.45 GHz radiofrequency fields alter gene expression on cultured
human cells. FEBS Letters. 2005; 579: 4829‐4836.
9. Demsia G, Vlastos D, Matthopoulos DP. Effect of 910‐MHz electromagnetic field on rat bone
marrow. The Scientific World Journal. 2004; 4(S2): 48‐54.
10. Lai H, Singh NP. Magnetic‐field‐induced DNA strand breaks in brain cells of the rat.
Environmental Health Perspectives. 2004; 112(6): 687‐694. Available from:
http://ehp03.niehs.nih.gov/article/info:doi/10.1289/ehp.6355
11. Mashevich M, Foldman D, Kesar, et al. Exposure of human peripheral blood lymphocytes to
electromagnetic fields associated with cellular phones leads to chromosomal instability.
Bioelectromagnetics. 2003; 24: 82‐90.
12. Magras IN, Xenos TD. RF radiation‐induced changes in the prenatal development of mice.
Bioelectromagnetics. 1997; 18:455‐461.
13. Ban R, Grosse Y, Lauby‐Secretan B, et al. Carcinogenicity of radiofrequency electromagnetic
fields. The Lancet Oncology. 2011; 12(7): 624‐626. Available from:

5
 http://www.thelancet.com/journals/lanonc/article/PIIS1470‐2045(11)70147‐
4/fulltext?_eventId=login
14. Hardell L, Carlberg M, Hansson Mild K. Use of cellular telephones and brain tumour risk in urban
and rural areas. Occup. Environ. Med. 2005; 62: 390‐394.
15. Nittby H, Brun A, Eberhardt J, et al. Increased blood‐brain barrier permeability in mammalian
brain 7 days after exposure to the radiation from a GSM‐900 mobile phone. Pathophysiology.
2009; 16: 103‐112.
16. Awad SM, Hassan NS. Health Risks of electromagnetic radiation from mobile phone on brain of
rats. J. Appl. Sci. Res. 2008; 4(12): 1994‐2000.
17. Leszczynski D, Joenvaara S. Non‐thermal activation of the hsp27/p38MAPK stress pathway by
mobile phone radiation in human endothelial cells: Molecular mechanism for cancer ‐ and
blood‐brain barrier – related effects. Differentiation. 2002; 70: 120‐129.
18. Santini R, Santini P, Danze JM, et al. Study of the health of people living in the vicinity of mobile
phone base stations: 1. Influences of distance and sex. Pathol Biol. 2002; 50: 369‐373.
19. Abdel‐Rassoul G, Abou El‐Fateh O, Abou Salem M, et al. Neurobehavioral effects among
inhabitants around mobile phone base stations. Neurotox. 2007; 28(2): 434‐440.
20. Hutter HP, Moshammer H, Wallner P, Kundi M. Subjective symptoms, sleeping problems, and
cognitive performance in subjects living near mobile phone base stations. Occup. Environ. Med.
2006; 63: 307‐313.
21. Kolodynski AA, Kolodynska VV. Motor and psychological functions of school children living in the
area of the Skrunda Radio Location Station in Latvia. Sci. Total Environ. 1996; 180: 87‐93.
22. Rea WJ, Pan Y, Fenyves EJ, et al. Electromagnetic field sensitivity. Journal of Bioelectricity. 1991;
10(1 &2): 243‐256.
23. McCarty DE, Carrubba S, Chesson AL, et al. Electromagnetic hypersensitivity: Evidence for a
novel neurological syndrome. Int. J. Neurosci. 2011; 121(12): 670‐676.
24. Ingole IV, Ghosh SK. Cell phone radiation and developing tissues in chick embryo – a light
microscopic study of kidneys. J. Anat. Soc. India. 2006; 55(2): 19‐23.
25. Lubec G, Wolf C. Bartosch B. Amino acid isomerisation and microwave exposure. Lancet. 1989;
334: 1392‐1393.
26. Smith CW. Quanta and coherence effects in water and living systems. Journal of Alternative and
Complimentary Medicine. 2004; 10(1): 69‐78.

6
27. Smith CW (2008) Fröhlich’s Interpretation of Biology through Theoretical Physics. In: Hyland GJ
and Rowlands P (Eds.) Herbert Fröhlich FRS: A physicist ahead of his time. Liverpool: University
of Liverpool, 2nd edition, pp 107‐154.
28. Del Giudice E, Doglia S, Milani M, et al. Magnetic flux quantization and Josephson behavior in
living systems. Physica Scripta. 1989; 40: 786‐791.
29. Tonomura A, Osakabe N, Matsuda T, et al. Evidence for Aharonov‐Bohm effect with magnetic
field completely shielded from electron wave. Phys. Rev. Let. 1986; 56(8):792‐75.
30. Del Giudice E, De Ninno A, Fleischmann, et al. Coherent quantum electrodynamics in living
matter. Electromagn. Biol. Med. 2005; 24: 199‐210.
31. Cardella C, de Magistris L, Florio E, Smith C. Permanent changes in the physic‐chemical
properties of water following exposure to resonant circuits. Journal of Scientific Exploration.
2001; 15(4): 501‐518.

7
AAP Headquarters
141 Northwest Point Blvd
December 12, 2012
Elk Grove Village, IL 60007-1019
Phone: 847/434-4000
Fax: 847/434-8000
The Honorable Dennis Kucinich
E-mail: [email protected] 2445 Rayburn House Office Building
www.aap.org
Washington, DC 20515
Reply to
Department of Federal Affairs
Homer Building, Suite 400 N Dear Representative Kucinich:
601 13th St NW
Washington, DC 20005
Phone: 202/347-8600 On behalf of the American Academy of Pediatrics (AAP), a non-profit professional
Fax: 202/393-6137 organization of 60,000 primary care pediatricians, pediatric medical sub-
E-mail: [email protected]
specialists, and pediatric surgical specialists dedicated to the health, safety and
Executive Committee well-being of infants, children, adolescents, and young adults, I would like to share
President our support of H.R. 6358, the Cell Phone Right to Know Act.
Thomas K. McInerny, MD, FAAP

President-Elect The AAP strongly supports H.R. 6358’s emphasis on examining the effects of
James M. Perrin, MD, FAAP
radiofrequency (RF) energy on vulnerable populations, including children and
Immediate Past President
Robert W. Block, MD, FAAP pregnant women. In addition, we are pleased that the bill would require the
Executive Director/CEO
consideration of those effects when developing maximum exposure standards.
Errol R. Alden, MD, FAAP Children are disproportionately affected by environmental exposures, including
Board of Directors
cell phone radiation. The differences in bone density and the amount of fluid in a
District I
child’s brain compared to an adult’s brain could allow children to absorb greater
Carole E. Allen, MD, FAAP quantities of RF energy deeper into their brains than adults. It is essential that any
Arlington, MA
new standards for cell phones or other wireless devices be based on protecting the
District II
Danielle Laraque, MD, FAAP
youngest and most vulnerable populations to ensure they are safeguarded through
Brooklyn, NY their lifetimes.
District III
David I. Bromberg, MD, FAAP
Frederick, MD
In addition, the AAP supports the product labeling requirements in H.R. 6358.
District IV These standards will ensure consumers can make informed choices in selecting
Francis E. Rushton, Jr, MD, FAAP mobile phone purchases. They will also enable parents to better understand the
Beaufort, SC
potential dangers of RF energy exposure and protect their children.
District V
Marilyn J. Bull, MD, FAAP
Indianapolis, IN On July 24, the U.S. Government Accountability Office (GAO) published a report
District VI on federal cell phone radiation exposure limits and testing requirements. The GAO
Pamela K. Shaw, MD, FAAP
Kansas City, KS noted that the Federal Communications Commission’s (FCC) most recent data
District VII indicates that the number of estimated mobile phone subscribers has grown from
Kenneth E. Matthews, MD, FAAP approximately 3.5 million in 1989 to approximately 289 million at the end of 2009.
College Station, TX
Cell phone use behaviors have also changed during that time. The quantity and
District VIII
Kyle Yasuda, MD, FAAP duration of cell phone calls has increased, as has the amount of time people use
Seattle, WA mobile phones, while cell phone and wireless technology has undergone substantial
District IX changes. Many more people, especially adolescents and young adults, now use cell
Stuart A. Cohen, MD, MPH, FAAP
San Diego, CA phones as their only phone line, and they begin using wireless phones at much
District X younger ages.
Sara H. Goza, MD, FAAP
Fayetteville, GA
Despite these dramatic changes in mobile phone technology and behavior, the FCC has not
revisited the standard for cell phone radiation exposure since 1996. The current FCC standard
for maximum radiation exposure levels is based on the heat emitted by mobile phones. These
guidelines specify exposure limits for hand-held wireless devices in terms of the Specific
Absorption Rate (SAR), which measures the rate the body absorbs radiofrequency (RF). The
current allowable SAR limit is 1.6 watts per kilogram (W/kg), as averaged over one gram of
tissue. Although wireless devices sold in the United States must ensure that they do not exceed
the maximum allowable SAR limit when operating at the device’s highest possible power level,
concerns have been raised that long-term RF energy exposure at this level affects the brain and
other tissues and may be connected to types of brain cancer, including glioma and meningioma.

In May 2011, the International Agency for Research on Cancer (IARC), the United Nations’
World Health Organization’s (WHO) agency promoting international cancer research
collaboration, classified RF energy as “possibly carcinogenic to humans.” In addition, the
National Cancer Institute has stated that although studies have not definitively linked RF energy
exposure from cell phones to cancer, more research is required to address rapidly changing cell
phone technology and use patterns.

This and other research identified by the GAO demonstrates the need for further research on this
issue, and makes clear that exposure standards should be reexamined.

The GAO concluded that the current exposure limits may not reflect the latest research on RF
energy, and that current mobile phone testing requirements may not identify maximum RF
energy exposure. The GAO proposed that the FCC formally reassess its limit and testing
requirements to determine whether they are effective. The AAP commends the activities
proposed under H.R. 6358, as they would address this research gap and improve consumer
knowledge and safety. Establishing an expanded federal research program as the basis for
exposure standards will ensure that consumer protections incorporate the latest research.
Currently, the National Institute of Health (NIH), the only federal agency the GAO identified as
directly funding research on this topic, provided approximately $35 million from 2001 to 2011.
Given this previous funding level, the AAP supports the $50 million per fiscal year for seven
years that H.R. 6358 would authorize.

The AAP appreciates your recognition of the need for new research and standards for mobile
phone radiation, and is pleased to support H.R. 6358. For further assistance, please do not
hesitate to contact Sonya Clay, Assistant Director, Department of Federal Affairs, at 202-347-
8600 or [email protected].

Sincerely,

Thomas K. McInerny, MD, FAAP

President
June 11, 2013 Ronald M. Powell, Ph.D.1

Biological Effects from RF Radiation at Low-Intensity Exposure,

based on the BioInitiative 2012 Report, and the
Implications for Smart Meters and Smart Appliances

Introduction and Conclusions

The Biological Effects Chart, at the end of this document, has been produced using data from a massive
new review of the medical research literature on the biological effects of electromagnetic fields. That
review is called the BioInitiative 2012 Report.2 The purpose of the Biological Effects Chart is to show the
radiofrequency (RF) exposure levels at which biological effects were found in 67 studies from the RF Color
Charts of the BioInitiative 2012 Report, and then to compare those exposure levels to the following:

(1) current FCC Maximum Permitted Exposure (MPE) limits that govern Smart Meters and Smart
Appliances in the United States
(2) new biologically based RF exposure limits proposed in the BioInitiative 2012 Report
(3) calculated RF exposure levels produced by a single Smart Meter at various distances
(4) calculated RF exposure levels produced by a single Smart Appliance at various distances

This comparison is based on RF exposure levels expressed as the RF power density (RF power per unit area).
This comparison does not address other potentially important factors such as carrier continuity (continuous
versus pulsed radiation) and modulation technique (the method used to impress information on the
carrier), among others. The purpose is to identify what biological effects arise from exposure to RF power
density levels like those produced by Smart Meters and Smart Appliances.

This comparison indicates the following:

(1) The current FCC Maximum Permitted Exposure (MPE) limits are so high that they provide no
protection for the public from the biological effects found in any of the 67 studies.

(2) New biologically based RF exposure limits proposed in the BioInitiative 2012 Report are 1 million
times lower than current FCC limits and would protect against the biological effects found in nearly
all of the 67 studies.

(3) A single Smart Meter on a home can produce RF exposure levels that caused the biological
effects found in either most or many of the 67 studies, depending on the distance from the Smart
Meter.

(4) A single Smart Appliance in the home can produce RF exposure levels that caused the biological
effects found in nearly half or fewer of the 67 studies, depending on the distance from the Smart
Appliance. Multiple Smart Appliances in a home multiply the total exposure.

1
The author holds a Ph.D. in Applied Physics from Harvard University, 1975.
2
BioInitiative Working Group, Cindy Sage and David O. Carpenter, Editors, BioInitiative Report: A Rationale for Biologically-based
Public Exposure Standards for Electromagnetic Radiation, December 31, 2012 ( http://www.bioinitiative.org ).
1
 (5) A single Smart Meter on a nearest neighbor’s home can produce RF exposure levels that caused
the biological effects found in many of the 67 studies. A given home may have one to eight nearest
neighbors, each with a Smart Meter, multiplying the total exposure in the given home.

Other observations:

(1) Most biological effects of RF exposure cannot be sensed by human beings. Examples are the
onset of cancer, DNA damage, and fertility effects. One category of effects that can often be sensed
includes neurological effects on sleep, memory, learning, and behavior.

(2) Unborn and very young children may be more affected by RF exposure than adults.

This document provides background information, an explanation of each feature of the Biological Effects
Chart, and a detailed discussion of each of the conclusions and observations summarized above. That
discussion begins on page 11.

Figure 1, on page 9 in this document, and the Biological Effects Chart, at the end of this document, are in
color, and are most easily understood when viewed in color. But they can also be understood in black and
white. To make that possible, key lines in Figure 1 and in the Biological Effects Chart are identified not only
by color but also by line thickness and line style (solid versus dashed).

Terminology for Parts of the Electromagnetic Spectrum

Electromagnetic fields occur over a wide range of frequencies, referred to as the electromagnetic
spectrum.3 But the terms used for parts of that spectrum are not consistently named or defined. The
BioInitiative 2012 Report uses the following definitions for two key parts of the electromagnetic spectrum:

extra low frequency (ELF): electromagnetic fields with frequencies from 1 to 300 Hz4
radiofrequency (RF): electromagnetic fields with frequencies from 100 kHz to 300 GHz5

Within the radiofrequencies lie the microwave frequencies. Microwaves, too, are variously defined. Here
are two common definitions:

microwaves: electromagnetic fields with frequencies from 300 MHz to 300 GHz6
microwaves: electromagnetic fields with frequencies from 1 GHz to 100 GHz7

This document focuses on the biological effects of the frequencies at which the following devices operate.
Those frequencies are shown in round numbers.

3
Explanation of units of measure for frequency: 1 hertz is 1 cycle per second. 1 kilohertz is equivalent to 1000 hertz.
1 megahertz is equivalent to 1000 kilohertz and to 1,000,000 hertz. 1 gigahertz is equivalent to 1000 megahertz and to
1,000,000 kilohertz and to 1,000,000,000 hertz. These units are abbreviated as follows: hertz (Hz), kilohertz (kHz),
megahertz (MHz), and gigahertz (GHz).
4
BioInitiative 2012 Report cited in footnote 2 on page 1, Section 26, Glossary of Terms and Abbreviations, page 3. The Report
notes that the term Extremely Low Frequency is used in Europe and the term Extra Low Frequency is used in the United States.
Wikipedia uses the term Extremely Low Frequency to refer to 3 to 300 hertz
( http://en.wikipedia.org/wiki/Extremely_low_frequency ).
5
BioInitiative 2012 Report cited in footnote 2 on page 1, Section 26, Glossary of Terms and Abbreviations, page 5.
6
( http://en.wikipedia.org/wiki/Microwaves )
7
( http://en.wikipedia.org/wiki/Microwaves )
2
 cell towers8 300, 400, 700, 800, 900, 950, 1800, 1900, 2100 MHz
Wi-Fi (most common type of WLAN)9 2400, 2500 MHz (predominant)
2600, 3600, 5000 MHz (emerging)
wireless laptops10 2400 MHz (predominant)
5000 MHz (emerging)
Smart Meters11 900, 2400 MHz (Smart Meters and Collector Smart Meters)
850 MHz (Collector Smart Meters only)
Smart Appliances12 2400 MHz

Note that that all of these devices operate at frequencies between 300 MHz and 5000 MHz. The
frequencies at which Smart Meters and Smart Appliances operate are right in the middle of this range.
According to one or more of the definitions given above, all of these frequencies may be referred to as
either radiofrequencies (RF) or microwaves. Since the BioInitiative 2012 Report refers to these frequencies
as radiofrequencies (RF), that term will be used here. But the term microwaves could have been used just
as well.

The BioInitiative 2012 Report

The BioInitiative 2012 Report was developed by an international group of 29 individuals with expertise on
the biological effects of electromagnetic fields, or on the related public-health issues.13 As a group, these
experts hold 20 PhD degrees, one DrSc degree, 9 MD degrees, one DVM degree, and four degrees of MSc,
MA, MPH, or MSPAS. These experts come from ten countries, each with the following number of
participants:

USA 10 India 2
Sweden 6 Italy 2
Austria 2 Denmark 1
Canada 2 Russia 1
Greece 2 Slovak Republic 1

The goal of the BioInitiative Report is to present “a solid scientific and public health policy assessment that
is evidence-based.” The report was prepared “independent of governments, existing bodies and industry
professional societies that have clung to old standards.”14

8
( http://en.wikipedia.org/wiki/Cellular_network ), ( http://en.wikipedia.org/wiki/GSM_frequency_bands ), and
( http://en.wikipedia.org/wiki/UMTS_frequency_bands )
9
( http://en.wikipedia.org/wiki/WI-FI ) and ( http://en.wikipedia.org/wiki/List_of_WLAN_channels )
10
( http://en.wikipedia.org/wiki/Wireless_LAN )
11
Both the Landis-Gyr FOCUS AXR-SD and the General Electric I-210+c Smart Meters, being installed in Maryland, have FCC ID
OWS-NIC514. They send and receive information in two microwave frequency ranges: (1) 902.3 to 926.9 MHz, and (2) 2405.8 to
2480.9 MHz ( http://stopsmartmeters.org/wp-content/uploads/2012/01/OWS-NIC514-FCC-specifications.pdf ). Collector Smart
Meters have a third transmission frequency of 850 MHz ( http://sagereports.com/smart-meter-rf/?page_id=210 ). They receive
and retransmit the signals from Smart Meters to assure that those signals reach the antennas of the electric power company. It
is not clear to me at this time whether Collector Smart Meters are employed in all installations of Smart Meters.
12
The most likely transmitter/receiver in the Smart Appliances is the so-called ZigBee device. ZigBee devices operate at 865 MHz
(in Europe) and 915 MHz (in the USA and Australia) as well as 2.4 GHz (worldwide) ( https://en.wikipedia.org/wiki/ZigBee ). But
the Smart Meters first observed in installations in Maryland seem to require that the ZigBee devices operate at 2.4 GHz.
13
BioInitiative 2012 Report cited in footnote 2 on page 1, cover page of the full report, as a single PDF file.
14
BioInitiative 2012 Report cited in footnote 2 on page 1 , Section i, Preface 2012, page 2.
3
The Scope of the BioInitiative 2012 Report

The 1479-page BioInitiative 2012 Report considers the “content and implications of about 1800 new
studies” since the last BioInitiative Report was published in 2007.15 The 2012 Report contains 16 chapters
that address key categories of biological effects. The 2012 Report also contains several chapters that
address key public policy issues, such as the nature and shortcomings of the current exposure standards,
and the bases for sufficient argument for changing those standards. Emphasized is the importance of
weighing the magnitude of potential harm against the evidence of potential harm, to determine when
protective action should be triggered.16 Since Smart Meters are being mandated for entire populations in
the United States, the magnitude of potential harm is considerable, so prudence dictates serious
consideration of the increasing evidence of harm.

The Data Source for the Biological Effects Chart

The data for the appended Biological Effects Chart were drawn from the so-called RF Color Charts in the
BioInitiative 2012 Report.17 The RF Color Charts contain two charts:

The first chart describes 67 studies of the biological effects of radiofrequency (RF) radiation.18 Each
study represents one or more biological effects found at a one value of the RF power density (RF
power per unit area) or within a range of such values. These data are especially useful when
considering whole-body exposure, which is the type of exposure that human beings receive from
Smart Meters at a distance of 1 meter or more.19 These data form the basis for the appended
Biological Effects Chart.

The second chart describes 68 studies of the biological effects of radiofrequency (RF) radiation.20 In
this chart, each study represents one or more biological effects found at one Specific Absorption
Rate, or SAR value, or within a range of such values. A SAR value is the RF power absorbed per unit
mass of the biological entity being irradiated. These data are especially useful when less than the
entire body is irradiated, and at very close distances, such as when a cell phone irradiates the head.

15
BioInitiative 2012 Report cited in footnote 2 on page 1 , Section 1, Summary for the Public and Conclusions, 2012 Supplement:
Summary for the Public – Ms. Sage, page 3.
16
BioInitiative 2012 Report, cited in footnote 2 on page 1, Table 1-1, Section 23: The Precautionary Principle, 2012 Supplement:
The Precautionary Principle – Mr. Gee, page 2.
17
BioInitiative 2012 Report, cited in footnote 2 on page 1, Section 1, Summary for the Public and Conclusions, Table 1-2 Reported
Biological Effects from Radiofrequency Radiation at Low-Intensity Exposure 2012, no page numbers.
18
Each study in the first chart derives from one publication. But three publications contributed two studies, and one publication
contributed three studies. As a result, the 67 studies derive from 62 publications. So the terms studies and publications have
slightly different meanings as used here.
19
More specifically, the power density values used in the first table are valid in the “far field” (also called the “radiative field”) of
the Smart Meter. For the type of antenna in a Smart Meter or a Collector Smart Meter, the far field should begin about two
wavelengths from the meter ( http://en.wikipedia.org/wiki/Far_field ). A Collector Smart Meter transmits on three frequencies
(850, 900, and 2400 MHz). The longest wavelength transmitted by a Collector Smart Meter is determined by the lowest
frequency which it transmits, which is 850 MHz. That wavelength is 0.35 meters (about 1 foot). A Smart Meter transmits on two
frequencies (900 MHz and 2400 MHz), so the lowest frequency transmitted by a Smart Meter is 900 MHz, and the longest
wavelength it transmits is 0.33 meters (again about 1 foot). Smart Appliances are expected to transmit at 2400 GHz, with has a
wavelength of 0.13 meters (about 5 inches). So for all three devices, the far field begins about 0.7 meters (about 2 feet), or less,
from them. This document addresses distances from 1 meter (about 3 feet) up, so all such distances are in the far field for all
three devices.
20
Each study in the second chart derives from one publication. But two publications contributed two studies each. As a result
the 68 studies derive from 66 publications. So the terms studies and publications have slightly different meanings as used here.
4
 This is not the usual case for RF exposure from Smart Meters, so these data were not used for the
appended Biological Effects Chart.

Criteria for Selection of the Studies in the RF Color Charts

The criteria used in the BioInitiative 2012 Report to select the studies for the RF Color Charts, and thus for
the appended Biological Effects Chart, were the following:21

(1) A selection of good examples only. Not intended to be comprehensive.

(2) Peer-reviewed and published studies only.
(3) Good exposure data (numeric).
(4) Author(s) have clear methods and conclusions.
(5) Cover wide range of topics, such as genotoxicity, neurological, immune, cancers, behavior,
attention, memory, sleep, etc.
(6) Cover wide range of exposure levels, with an emphasis on the lowest levels and the more
recent studies.

Every study in the first chart of the RF Color Charts, and thus every study in the appended Biological Effects
Chart based on that first chart, except one (Dumansky, 1974), was published after 1986. 1986 is the year of
publication of the document on which the current FCC Maximum Permitted Exposure (MPE) limits are
principally based.22 That was 27 years ago, which is one factor in explaining why the current FCC MPE limits
are out of date. The references for the studies in the RF Color Charts, and thus for the biological effects
data in the appended Biological Effects Chart, are included in the reference list that immediately follows
the RF Color Charts in the PDF file of the full BioInitiative 2012 Report.23

Explanation of the Appended Biological Effects Chart

The Horizontal Axis of the Biological Effects Chart

The studies are presented in order of increasing RF power density along the horizontal axis of the Biological
Effects Chart. That order facilitates comparing effects observed at similar RF power densities. Each
position along the horizontal axis of the Biological Effects Chart represents one study whose principal
author and date of publication are written under that axis. The studies could just as well have been
ordered alphabetically by the authors’ last names, or numerically by the publication dates.

The Vertical Axis of the Biological Effects Chart

The vertical axis represents the RF power densities at which each study was conducted. These power
densities cover a wide range of values, so a logarithmic vertical axis was employed. This approach
permitted displaying 11 orders of magnitude on the Biological Effects Chart.24 The units of measure

21
The criteria were provided by Cindy Sage, co-editor of BioInitiative 2012, in a private communication, April 23, 2013.
22
The current FCC exposure limits are based principally on a 1986 publication of the National Council on Radiation Protection
and Measurements (NCRP). That publication is “Report No. 086 - Biological Effects and Exposure Criteria for Radiofrequency
Electromagnetic Fields”. The NCRP was chartered by the U.S. Congress in 1964, but is not a Government agency and is not
subject to oversight by the Congress.
23
BioInitiative 2012 Report cited in footnote 2 on page 1, Reported Biological Effects from Radiofrequency Radiation (RFR) at
Low-Intensity Exposure Levels, sequential pages 112-121 in the 1479-page PDF version of the full Report.
24
Each order of magnitude is a factor of 10.
5
selected for the vertical axis are milliwatts per square meter (mW/m2).25 These units work well for the
wide range of power densities required for the vertical axis, making the length of the smallest number,
0.000001, not too much longer than the length of the largest number, 10000.

The selected units for the vertical axis also work well for relating the RF power density shown to the total
RF power that an adult human would receive. The surface area of an adult human is about 2 square meters
(m2).26 So the surface area that an adult human presents to an RF wave arriving from the front, or from the
back, is about 1 square meter (m2). So when an adult human faces an oncoming wave of radiation with a
power density of, say, 10 milliwatts per square meter (mW/m2), that human will receive a total of 10
milliwatts (mW) of radiation over the entire body. That is, the number describing the power density will be
the same as the number describing the total power received, even though the units of measure are
different in the two cases. So, when examining the vertical axis of the attached Biological Effects Chart,
each number on that axis may be taken to mean both the power density (in mW/m2) of the oncoming wave
of RF radiation and the total RF power (in mW) received by an adult human when standing with the front,
or the back, facing the direction from which the radiation is coming.

The Round Red Dots on the Biological Effects Chart

Each round red dot • on the attached Biological Effects Chart indicates the RF power density at which the
study named on the horizontal axis, directly below the dot, was conducted. Some studies were conducted
over a range of power densities. In such cases, the average value of the high and low ends of the range
determines the location of the dot on the vertical axis. The range of power densities applicable is shown as
a black vertical line through the dot. The top of the vertical line marks the high end of the range, and the
bottom of the vertical line marks the low end of the range. On those vertical lines, the dots appear higher
than the middle. That effect results from the logarithmic vertical axis, even though the dots are located at
the true average value of the high and low ends of the range.

The Alphabetic Codes above the Dots on the Biological Effects Chart

A one- or two-letter code appears just above each of the dots on the Biological Effects Chart. Each code,
such as “CB”, identifies the category into which the biological effects found by a given study fall. Those
one- and two-letter codes are translated in the table on the Biological Effects Chart, first into the one or
two words represented by the letters of the codes, and then into a fuller description of the category, as
reported in the RF Color Charts of the BioInitiative 2012 Report. For example, the code “CB” stands for the
words “Cancer, Brain” and represents a category that contains “Brain tumors and blood-brain barrier”.27
Similarly, the code “CO” stands for the words “Cancer, Other” and represents a category that contains
“Cancer (other than brain), cell proliferation”.

The Thick Horizontal Blue Line at the Top of the Biological Effects Chart

The thick horizontal blue line, which appears at the top of the Biological Effects Chart, represents the
Maximum Permitted Exposure (MPE) limits of the Federal Communications Commission (FCC). These are
the limits applicable to the general population for uncontrolled exposure for the frequencies that Smart

25
1 milliwatt (mW) is one-thousandth of a watt (W).
26 2 2
The surface area of a man is about 1.9 square meters (m ); and the surface area of a woman is about 1.6 square meters (m ),
both according to Wikipedia ( http://en.wikipedia.org/wiki/Body_surface_area ).
27
The reference to blood-brain barrier refers to the weakening of the barrier that the body erects between the blood and the
brain to prevent harmful entities circulating in the blood from entering the brain.
6
Meters, Collector Smart Meters, and Smart Appliances use: 2400 MHz, 900 MHz, and 850 MHz. The top
edge of the blue line is the limit applicable to 2400 MHz. The bottom edge of the blue line is the limit
applicable to 850 MHz. The limit applicable to 900 MHz falls in between.

Frequency FCC Maximum Permitted Exposure (MPE) Limits28

(MHz) (mW/m2)

2400 10,000 (Smart Meters, Collector Smart Meters, and Smart Appliances)
900 6000 (Smart Meters and Collector Smart Meters)
850 5700 (Collector Smart Meters)

However, those FCC limits apply to the time-average RF power density over a period of 30 minutes. So,
pulsed signals, like those issued by Smart Meters and Smart Appliances, are permitted to assume even
higher peak values, as long as the time-average over a period of 30 minutes is below the FCC limits shown.

The Thick Horizontal Yellow Line on the Biological Effects Chart

The thick horizontal yellow line, which appears about one-third from the bottom of the Biological Effects
Chart, shows the new RF exposure limits proposed in the BioInitiative 2012 Report for chronic exposure to
pulsed radiation. Pulsed radiation is the type of radiation that Smart Meters and Smart Appliances emit.
The top of this line is located at 0.006 milliwatts per square meter (mW/m2). The bottom of this line is
located at 0.003 milliwatts per square meter (mW/m2).29

New Biologically Based RF Exposure Limits Proposed in the BioInitiative 2012 Report30
(as expressed, equivalently, in various units of measure)

0.3 to 0.6 nanowatts per square centimeter (nW/cm2) (units used in BioInitiative 2012)
0.003 to 0.006 milliwatts per square meter (mW/m2) (units used in appended Chart)
3 to 6 microwatts per square meter (μW/m2)

The data from the 67 studies in the Biological Effects Chart indicate why this level might have been judged
appropriate by the authors of the BioInitiative 2012 Report: This level would protect against the biological
effects found by all but five of the 67 studies. The BioInitiative 2012 Report indicates that these proposed
new limits “may need to change in the future, as new and better studies are completed.” 31 Note that this
level, which can also be expressed as 3 to 6 microwatts per square meter (μW/m2), is in agreement with
the level of 5 microwatts per square meter (μW/m2) proposed by Dietrich Klinghardt, M.D., Ph.D., in his
detailed video treatment of the health hazards of Smart Meters.32

28
Questions and Answers about Biological Effects and Potential Hazards of Radiofrequency Electromagnetic Fields, OET (Office of
Engineering and Technology) Bulletin 56, Fourth Edition, Federal Communications Commission, August 1999. See Table 1(B),
Limits for General Population/Uncontrolled Exposure, page 15.
( http://www.fcc.gov/Bureaus/Engineering_Technology/Documents/bulletins/oet56/oet56e4.pdf )
29
BioInitiative 2012 Report cited in footnote 2 on page 1 , Section 1, Summary for the Public and Conclusions, 2012 Supplement:
Summary for the Public – Ms. Sage, pages 25-26.
30
1 milliwatt (mW) is one thousandth of a watt (W). 1 microwatt (μW) is one millionth of a watt (W). 1 nanowatt (nW) is one
2
billionth of a watt (W). 1 centimeter (cm) is one hundredth of a meter (m). So, 1 square centimeter (cm ) is one ten thousandth
2
of 1 square meter (m ).
31
See footnote 29 above.
32
Dr. Klinghardt’s video, and further information about him, can be found on the following web sites:
( http://marylandsmartmeterawareness.org/smart-meter-news/dr-dietrich-klinghardt-smart-meters-emr-the-health-crisis-of-
our-time ) and ( http://www.klinghardtacademy.com/BioData/Dr-Dietrich-Klinghardt.html ).
7
The Thin Horizontal Green Lines on the Biological Effects Chart

The four thin horizontal green lines show the power density of the RF radiation emitted by a Smart Meter
at four different distances. To determine these levels, I assumed that the Smart Meter is the type being
installed in Maryland, as described in footnote 11 on page 3:

P = RF power output = 1 watt

g = antenna gain = 4 dBi = 2.5 (a pure number, a ratio)33

This Smart Meter has an RF power output, P, of approximately 1 watt. The antenna used in the Smart
Meter is a variation of a vertical dipole antenna which provides a gain, g, of 4 dBi, or 2.5, in the horizontal
direction. I have not accounted for absorption by obstructions, such as walls and other objects, which can
lower RF power density levels. Nor have I accounted for reflections from walls or other objects, which can
raise or lower RF power density levels. So the actual power densities would likely fall somewhere between
the two extremes that could apply if these other factors had been considered. The RF power density, PD, in
watts per square meter (W/m2) can be calculated from this equation:

ܲ
ܲ஽ ൌ ݃ ൤ ଶ൨
Ͷߨ‫ݎ‬

In the above equation, r is the distance, in meters, from the Smart Meter, in the horizontal direction. This
equation can be understood this way: The radiation from the Smart Meter travels outward from the meter
and is initially regarded as spreading uniformly over the surface of a sphere (centered on the Smart Meter)
which has a radius, r, and thus a surface area of 4πr2. So the part of the equation in square brackets [ ]
indicates the power density that would be produced, at a distance, r, if the radiation from the Smart Meter
spread uniformly over the surface of that sphere. The antenna used in the Smart Meter increases the
power density in the horizontal direction, at the expense of a decrease in the power density in the vertical
direction, because all receivers of interest are in the horizontal direction. Those receivers include the
antennas of the electric power company and the antennas of other Smart Meters in the area with which a
given Smart Meter communicates. The antenna gain, g, accounts for this characteristic of the antenna and
causes PD to represent the power density in the horizontal direction.

The RF power density, PD, computed from the above equation is plotted in Figure 1 on page 9 as a function
of the distance from the Smart Meter. The power density is expressed in units of milliwatts per square
meter (mW/m2) to match the units in the Biological Effects Chart under discussion. A logarithmic vertical
axis is used for the power density, again to match the logarithmic vertical axis of the Biological Effects
Chart. The vertical axis appears on both sides of Figure 1 to facilitate easier reading.

The power density is strongest near the Smart Meter and falls off quickly with increasing distance, but
persists at lower levels to great distances. The power density of the Smart Meter drops to the maximum
33
The antenna gain, g, is usually specified in dBi, which means the gain, in decibels, relative to an ideal isotropic antenna, which
is an idealized antenna that radiates equally in all directions. The gain of the antenna in a Smart Meter (with FCC ID
OWS-NIC514) is 4 dBi and translates to a factor of 2.5. That is, the power density in the horizontal direction is 2.5 times greater
than it would be if the antenna radiated equally in all directions. In the case of Smart Meters, the power density in the vertical
direction is reduced in favor of increased power density in the horizontal direction where all intended receivers are located. To
access the reference, start at ( http://transition.fcc.gov/oet/ea/fccid ). In the box Grantee Code, enter OWS. In the box Product
Code, enter –NIC514 (including the hyphen), press Search, click on the first entry Detail, and click on Test Report. This should
take you to this location ( https://apps.fcc.gov/eas/GetApplicationAttachment.html?id=1174749 ) which you cannot address
directly. Then see page 3 of 66 of the document found.
8
exposure level proposed in the BioInitiative 2012 Report at a distance of about 180 meters. On the
appended Biological Effects Chart, the four thin horizontal green lines show the power densities, taken
from Figure 1, for distances of 1 meter (3 feet), 5 meters (16 feet), 20 meters (66 feet), and 100 meters
(328 feet).

Figure 1: Smart Meter and Smart Appliance RF Power Densities versus Distance

10000 FCC Maximum Permitted Exposure to Frequencies Used by Smart Meters 10000
(for continuous radiation; no absolute limit for pulsed radiation)

1000 1000

100 100

SMART METER ASSUMPTIONS

10 RF Power Output = 1 watt 10
Antenna Gain = 4 dBi = 2.5
Power Density (mW/m2)

Propagation
no absorption
1 no reflection 1

Smart Meter
0.1 0.1

0.01 0.01
New RF exposure limits proposed in BioInitiative 2012 for chronic exposure to pulsed radiation

0.001 0.001

Smart Appliance
0.0001 0.0001
SMART APPLIANCE ASSUMPTIONS
RF Power Output = 0.1 watt
Antenna Gain = 3 dBi = 2
0.00001 Propagation 0.00001
no absorption
no reflection
0.000001 0.000001
0 20 40 60 80 100 120 140 160 180 200
Distance from Smart Meter or Smart Appliance (m)

The Thin Dashed Horizontal Blue Lines on the Biological Effects Chart

Smart Meters are designed to communicate wirelessly with new Smart Appliances that are now becoming
available. The Smart Appliances contain RF transmitters and receivers of their own. Through the Smart
Meters, the Smart Appliances can report, to the electric power company, data sufficient to identify the
specific appliances and to indicate when they were installed or removed, and how much power they are

9
consuming throughout the day and the night, every day of the year. Less certain is whether the electric
power company will be able to turn off the Smart Appliances by sending a wireless signal to them through
the Smart Meter. (For example, the electric power company might want to turn off appliances that draw a
lot of electricity at certain times of day, and in certain seasons, when the load on the electric power system
is high. An example would be turning off the air-conditioner at midday in midsummer.)

Such Smart Appliances will increase the RF radiation inside each home. Verifiable data on the actual RF
power output of the transmitters that will be used in the Smart Appliances is hard to find at present; but a
likely value is 0.1 watt, since that is a common value used for other short-range wireless devices.34 The
antenna gain is assumed to be 3 dBi or 2.35 The frequency of operation is assumed to be 2.4 GHz to
communicate with the Smart Meters.36

The RF power density for Smart Appliances is calculated with the same equation used for Smart Meters
above but with the different values for P and g just cited:

P = RF power output = 0.1 watt

g = antenna gain = 3 dBi = 2 (a pure number, a ratio)

The result for a single Smart Appliance is shown by the dashed blue line in Figure 1 on page 9. Once again, I
have not accounted for absorption and reflection during propagation. Absorption can lower the power
density. Reflection can lower or raise the power density. So the power densities shown in Figure 1 would
likely fall somewhere between the two extremes that could apply if these other factors had been
considered. The patterns of absorption and reflection inside homes vary greatly, so many different
situations are possible.

The power density from a single Smart Appliance does not fall to the new maximum exposure level
proposed in the BioInitiative 2012 Report until a distance of 50 meters (164 feet) from the Smart Appliance
has been reached. So there will be no location within the typical home that will be that far from a Smart
Appliance. Of course, over time, many such Smart Appliances may be purchased for a home, multiplying
the total exposure produced.

In the appended Biological Effects Chart, the thin dashed blue lines show the RF power density, taken from
Figure 1, for a single Smart Appliance at three distances: 1 meter (3 feet), 3 meters (10 feet), and
10 meters (33 feet) from the Smart Appliance. 10 meters is about at far from a Smart Appliance as a
person can get inside the typical home with a single centrally located Smart Appliance.

34
The most likely transmitter/receiver in the Smart Appliances is the so-called ZigBee device. These devices have RF outputs
ranging from 0.001 watt to 0.1 watt, which is equivalent to a range of 1 milliwatt (mW) to 100 milliwatts (mW).
( https://en.wikipedia.org/wiki/ZigBee )
35
The assumed gain¸ g, in this case, is 3 dBi, which is based on the performance of an ordinary vertical dipole antenna. That is,
the power density in the horizontal direction is 2 times greater than it would be if the antenna radiated equally in all directions.
36
ZigBee devices operate at 865 (in Europe) and 915 MHz (in the USA and Australia), as well as 2.4 GHz (worldwide); but the
design of the Smart Meters installed in Maryland seems to require that the ZigBee devices operate at 2.4 GHz.
( https://en.wikipedia.org/wiki/ZigBee )
10
Conclusions and Observations
Current FCC Maximum Permitted Exposure (MPE) Limits Are Too High to Protect the
Public

Because the FCC Maximum Permitted Exposure (MPE) limits are at power densities higher than the power
densities addressed in all of the 67 studies, those limits provide no protection against the biological effects
found in any of the 67 studies, no matter what the source of the RF radiation.

Further, the FCC Maximum Permitted Exposure limits apply to each source of radiation, individually, not to
the combined exposure from all sources. But a person will generally be exposed to radiation from a
combination of sources. So the FCC Maximum Permitted Exposure limits not only are too high to protect a
person from a single source of radiation, but also do not consider the actual exposure received by a person
from multiple sources of radiation.

New Biologically Based RF Exposure Limits, Proposed in the BioInitiative 2012

Report, are 1 Million Times Lower than the FCC Limits, to Protect the Public

The new RF exposure limits proposed in the BioInitiative 2012 Report are about 1 million times lower
(stricter) than the current FCC Maximum Permitted Exposure Limits in the frequency ranges at which Smart
Meters, Collector Smart Meters, and Smart Appliances operate.

Comparison of RF Exposure Limits

BioInitiative 2012 Report (RF) FCC MPE (850 to 2400 MHz) Ratio (FCC/BioInitiative 2012)

.003 to .006 mW/m2 5700 to 10,000 mW/m2 950,000 to 3,000,000

As shown in the appended Biological Effects Chart, the new RF exposure limits in the BioInitiative 2012
Report are low enough to protect against the biological effects found in nearly all of the 67 studies covered
by that Chart.

A Single Smart Meter Can Produce RF Power Density Levels Shown to Cause
Biological Effects

The Biological Effects Chart enables a comparison between the RF power densities produced by a Smart
Meter, at various distances from that Smart Meter, and the RF power densities that triggered biological
effects in the 67 studies.

The power density at 1 meter (3 feet) from a Smart Meter is higher than the power density that
triggered biological effects in 50 of the 67 studies.

The power density at 5 meters (16 feet) from a Smart Meter is higher than the power density that
triggered biological effects in 26 of the 67 studies.

The power density at 20 meters (66 feet) from a Smart Meter is higher than the power density that
triggered biological effects in 14 of the 67 studies.

11
 This distance of 20 meters is likely as far from a Smart Meter as a person can get and still be
inside the typical home. So living and sleeping on the side of a home that is farthest from
the Smart Meter is helpful but still may not reduce the received power densities to biological
insignificance. Further, one or more of the neighbors’ Smart Meters may be closer and may
thus be the stronger source.

The power density at 100 meters (328 feet) from a Smart Meter is higher than the power density
that triggered biological effects in 6 of the 67 studies.

So, even at the distance of a football field from the Smart Meter, the power density received
may still be biologically significant.

As shown in Figure 1, the RF power density from a Smart Meter does not drop down to the level of the
proposed new RF exposure limits until distances of 180 to 200 meters from the Smart Meter are reached.
In most residential communities, whether composed of single-family homes, townhomes, or apartments, it
will not be possible to get sufficiently far away from all of the Smart Meters present in that community.

A Single Smart Appliance inside a Home Can Produce RF Power Density Levels
Shown to Cause Biological Effects

Unfortunately, the problem of excess exposure to RF radiation will get worse as Smart Appliances are
adopted. They contain their own internal RF transmitters and receivers. Those Smart Appliances are
designed to communicate with Smart Meters and to report through the Smart Meters to the electric power
company. The data the Smart Appliances report will be sufficient for the electric power company to
identify which appliances you own, when you use them, and how much power they consume, throughout
the day and the night. The electric power company may even be able to turn the Smart Appliances off by
sending a wireless signal to the Smart Meter that is then transferred to the Smart Appliances, but that is
less certain at this time.

When these Smart Appliances are installed in a home, they will significantly increase the radiation levels in
that home for several reasons:

They will begin transmitting, and from distances very close to the residents.

The number of Smart Appliances in the home may increase with time as the residents gradually
replace their old appliances with new Smart Appliances, increasing the total radiation level.

The Smart Meters will transmit more frequently, in order to communicate with the Smart
Appliances.

Even a single Smart Appliance can produce RF power densities of concern. An inspection of the appended
Biological Effects Chart indicates the following:

The power density at 1 meter (3 feet) from a Smart Appliance is higher than the power density that
triggered biological effects in 32 of the 67 studies.

The power density at 3 meters (10 feet) from a Smart Appliance is higher than the power density
12
 that triggered biological effects in 21 of the 67 studies.

The power density at 10 meters (33 feet) from a Smart Appliance is higher than the power density
that triggered biological effects in 10 of the 67 studies.

These observations do not bode well for having 5, 10, or 15 Smart Appliances in a home. The RF radiation
from even a few Smart Appliances, because they will be so close to the residents, may rival that of a home’s
more distant Smart Meter. And the RF radiation from a large number of Smart Appliances may exceed that
of a home’s Smart Meter.

A Single Smart Meter on a Neighbor’s Home Can Produce RF Power Density Levels
Shown to Cause Biological Effects

For some locations in a given home, the distance to a neighbor’s Smart Meter may be less than the distance
to the resident’s own Smart Meter. Thus, a neighbor’s Smart Meter may be the principal source of
radiation for some locations in the given home. The Biological Effects Chart shows that a single Smart
Meter can produce RF power densities found to cause biological effects even at distances greater than 20
meters, and certainly up to 100 meters. And the number of neighbors within that range can be large. A
given single-family home in a residential community may have one to eight nearest neighbors, and even
more next nearest neighbors, all within 100 meters (328 feet) of a given home, and each with a Smart
Meter.

The problem of exposure from the neighbors’ Smart Meters becomes more serious as the distances
between adjacent homes, and thus the distances between adjacent Smart Meters, get smaller. So,
generally speaking, residents of townhouses will receive more radiation from their neighbors’ Smart Meters
than residents of single-family homes. And residents of apartments will receive even more radiation from
their neighbors’ Smart Meters, depending on the location of the Smart Meters in the apartment buildings.

So Smart Meters are a community concern, not just an individual concern. To resolve the problems of RF
exposure for a given home, it will be necessary to address all of the Smart Meters near that home. Smart
Appliances, too, contribute to this concern. While, individually, they have a lower RF power output than a
Smart Meter, the Smart Appliances of neighbors can also increase the RF exposure in the given home.

Fortunately, some states have offered an individual OPT OUT from the installation of a Smart Meter.37
While such an OPT OUT is very helpful, and is definitely the vital first step, the data on biological effects
discussed here suggest the limitations of such an OPT OUT in resolving the problem of excess radiation
from Smart Meters. There is no substitute for a roll back of all Smart Meters at the community level, or
higher.

Most Biological Effects of RF Radiation Cannot be Sensed by Human Beings

Most biological effects of RF radiation cannot be sensed by human beings. This fact is evident from an
inspection of the categories of biological effects from the RF Color Charts in the BioInitiative 2012 Report,
as shown below. For example, humans cannot sense the onset of cancer, DNA damage, or fertility effects.

37
Maryland, through the Maryland Public Service Commission, currently offers a temporary OPT OUT, with the future of that
OPT OUT yet to be decided. And the Maryland House of Delegates is currently considering legislation (HB1038) that would make
the OPT OUT permanent and would provide other protections for Maryland homeowners.
13
 Categories of Biological Effects in the RF Color Charts of the BioInitiative 2012 Report

Code Code Translation Biological Effects Category

CB Cancer, Brain Brain tumors and blood-brain barrier

CO Cancer, Other Cancer (other than brain), cell proliferation
H Heart Cardiac, heart muscle, blood-pressure, vascular effects
MC Metabolism, Calcium Disrupted calcium metabolism
OD Oxidation, DNA Oxidative damage/ROS/DNA damage/DNA repair failure
R Reproduction Reproduction/fertility effects
S Sleep Sleep, neuron firing rate, EEG, memory, learning, behavior
SI Stress, Immune Stress proteins, HSP,38 disrupted immune function

The principal category of biological effects that humans can often sense is the S (or Sleep) category. This
category includes neurological effects on sleep, memory, learning, and behavior, among others.
Unfortunately, not sensing these particular effects does not guarantee that other biological effects are not
occurring.

RF Radiation May Affect Unborn and Very Young Children More Severely than
Adults

The BioInitiative 2012 Report presents evidence that unborn and very young children may be more greatly
affected by RF radiation than adults because unborn and very young children are in “critical phases of
growth and development”.39

Concern for unborn and very young children is shared by the American Academy of Pediatrics (AAP) which
wrote to the U.S. Congress in support of a bill before the U.S. House of Representatives (H.R. 6358).40 This
bill would fund development of better founded RF exposure limits to protect against cell phones and other
wireless sources of RF radiation. The AAP made the following statement:

The AAP strongly supports H.R. 6358’s emphasis on examining the effects of radiofrequency (RF)
energy on vulnerable populations, including children and pregnant women. In addition, we are
pleased that the bill would require the consideration of those effects when developing maximum
exposure standards. Children are disproportionately affected by environmental exposures, including
cell phone radiation. The differences in bone density and the amount of fluid in a child’s brain
compared to an adult’s brain could allow children to absorb greater quantities of RF energy deeper
into their brains than adults. It is essential that any new standards for cell phones or other wireless
devices be based on protecting the youngest and most vulnerable populations to ensure they are
safeguarded through their lifetimes.41

38
HSP stands for Heat Shock Proteins. BioInitiative 2012 Report, cited in footnote 2 on page 1, Section 1, Summary for the Public
and Conclusions, Table 1-2 Reported Biological Effects from Radiofrequency Radiation at Low-Intensity Exposure 2012, no page
numbers.
39
BioInitiative 2012 Report cited in footnote 2 on page 1, Section 1: Summary for the Public and Conclusions, 2012 Supplement:
Summary for the Public – Ms. Sage, pages 8-10.
40
Summary of H.R. 6358 can be found here:
( http://marylandsmartmeterawareness.org/smart-meter-news/ask-your-congressional-rep-to-co-sponsor-h-r-6358 ). Full copy
of H.R. 6358 can be found here: ( http://thomas.loc.gov/home/gpoxmlc112/h6358_ih.xml ).
41
( http://ehtrust.org/wp-content/uploads/2012/12/aap_support_letter_cell_phone_right_to_know_act.pdf )
14
Smart Meters and Smart Appliances operate in the same frequency ranges as cell phones. Further, Smart
Meters have twice the RF power output of the typical cell phone, as shown in the table below, and will be
transmitting day and night. Emerging Smart Appliances will likely have about one-fifth the RF power output
of the typical cell phone. But a given home may have several Smart Appliances; and they, too, will be
transmitting day and night.

Device RF Power Output

Smart Meter42 1.115 watts which is 1115 milliwatts

Typical leakage from a microwave oven43 1 watt which is 1000 milliwatts
Typical cell phone43 0.5 watt which is 500 milliwatts
Wireless LAN (802.11a)43 0.251 watt which is 251 milliwatts
Wireless LAN (802.11n)43 0.250 watt which is 250 milliwatts
Cordless phone44 0.230 watt which is 230 milliwatts
Smart Appliance45 0.100 watt which is 100 milliwatts
Wireless LAN (802.11 b, g)43 0.100 watt which is 100 milliwatts
Typical laptop wireless LAN (Wi-Fi)43 0.032 watt which is 32 milliwatts

A Final Note
The Smart Meter is the first source of RF exposure that is mandated for installation in every home in an
entire region without the informed consent, or any consent, of the residents, and that is not under the
control of the residents.

For other sources of RF exposure in the home, the residents have a choice to use them, or not to use them,
and how often, and how long. Some of those other sources are included in the table above.

The Smart Appliances, while not mandated, will be the second source of RF exposure in a home that is not
under the control of the residents -- if manufacturers of the Smart Appliances provide no way of turning
off the RF transmitters in those appliances.

The only solution for the individual homeowner, at present, is the removal of the Smart Meter and the
avoidance of the Smart Appliances. This is a vital first step; but it is only a partial solution for a given home,
because the radiation from the neighbors’ Smart Meters and Smart Appliances will cross property
boundaries. Collaboration with the neighbors on reducing exposure levels is needed; and a solution at the
community level, or higher, will be even more effective.

42
The Landis+Gyr FOCUS AXR-SD and the General Electric I-210+c, being installed in Maryland, have FCC-ID OWS-NIC514 which
indicates that they send and receive information in two microwave frequency ranges: (1) 902.3 to 926.9 MHz, and (2) 2405.8 to
2480.9 MHz. The RF power output in the first frequency range is 0.968 watts. The RF power output in the second frequency
range is 0.147 watt. These values sum to the 1.115 watts shown here, to provide an indication of the total RF power output
capability of a Smart Meter. I have used an approximate value of 1 watt for the RF power output of a Smart Meter throughout
this document ( http://stopsmartmeters.org/wp-content/uploads/2012/01/OWS-NIC514-FCC-specifications.pdf ).
43
The RF power output levels come from this web site: ( http://en.wikipedia.org/wiki/DBm ). 1 watt equals 1000 milliwatts.
44
Panasonic specifies the power output of its DECT 6.0 cordless telephone Model KXTG1061 as 115 milliwatts for the handset
and another 115 milliwatts for the base station, for a total capability of 230 milliwatts.
45
For a reference, see footnote 34 on page 10.
15
 June 11, 2013 Reported Biological Effects from RF Radiation at Low-Intensity Exposure Ronald M. Powell, Ph.D.
in Each of the 67 Studies Referenced in the "BioInitiative 2012" Report
(Cell Tower, Wi-Fi, Wireless Laptop, and Smart Meter Power Densities)
Reference for data dots (red), data range indicators (verticalblack lines through red dots), biological effects categories for the red dots, and new proposed limits (yellow line): BioInitiative Working Group,
Cindy Sage and David O. Carpenter, Editors. BioInitiative Report: A Rationale for Biologically-based Public Exposure Standards for Electromagnetic Radiation at www.bioinitiative.org, December 31, 2012. For
references for other information on this chart, including the FCC Maximum Permitted Exposure limits, and the power densities of Smart Meters and Smart Appliances, see accompanying paper.

10000 FCC Maximum Permitted Exposure to Frequencies used by Smart Meters (for continuous radiation; no absolute limit for pulsed radiation)
MC R
CO SI SI R CB
1000 SI R CB SI
R SI S CB
SI OD
Power density 1 meter (3 feet) from Smart Meter S S MC SI CB
S
100 CO S CO CO SI SI OD S OD
SI
MC
OD
Power density 1 meter (3 feet) from Smart Appliance R S R CB SI SI S R S
Power Density (mW/m2)

10 R Power density 5 meters (16 feet) from Smart Meter

MC
S H S R S S S Power density 3 meters (10 feet) from Smart Appliance
1 S S S S Power density 20 meters (66 feet) from Smart Meter
S Power density 10 meters (33 feet) from Smart Appliance
S SI
0.1 S

Power density 100 meters (328 feet) from Smart Meter

CB
0.01 R
CO
New RF exposure limits proposed in BioInitiative 2012 for chronic exposure to pulsed radiation
OD

67 studies
SMART METER ASSUMPTIONS CODE CODE TRANSLATION BIOLOGICAL EFFECTS CATEGORY
0.001

50 studies
RF Power Output = 1 watt
CB Cancer, Brain Brain tumors and blood-brain barrier
Antenna Gain = 4 dBi = 2.5
CO Cancer, Other Cancer (other than brain), cell proliferation

26 studies
Propagation
0.0001 H Heart Cardiac, heart muscle, blood-pressure, vascular effects

14 studies
CO no absorption, no reflection
MC Metabolism , Calcium Disrupted calcium metabolism

6 studies
SMART APPLIANCE ASSUMPTIONS
RF Power Output = 0.1 watt OD Oxidation, DNA Oxidative damage/ROS/DNA damage/DNA repair failure
0.00001 Antenna Gain = 3 dBi = 2.0 R Reproduction Reproduction/fertility effects
Propagation S Sleep Sleep, neuron firing rate, EEG, memory, learning, behavior
OD no absorption, no reflection SI Stress, Immune Stress proteins, HSP, disrupted immune function
0.000001
Velizarov, 1999

Mohler, 2010
Oberfeld, 2004

Navarro, 2003

Pyrpasopoulou, 2004

Sarimov, 2004

Mann, 1998

Veyret, 1991

Mann, 1996
Belyaev, 1997

Belyaev, 1997

Otitoloju, 2010

Saunders, 1981

Dolk, 1997

Boscolo, 2001

Phillips, 1998

Marinelli, 2004

Navakatikian, 1994

Salford, 2003

Somozy, 1991

Lebedeva, 2000

Belyaev, 2005
Elekes, 1996
Navakatikian, 1994
Salford, 1994
Somozy, 1993
Navakatikian, 1994
Grundler, 1992

Thomas, 2008
Thomas, 2008
Thomas, 2010

Zwamborn, 2003
Kolodynski, 1996

Magras & Xenos, 1997

Persson, 1997
Fesenko, 1999

Eltiti, 2007

Kesari, 2008
Wolke, 1996
D'Inzeo, 1988

Dumansky, 1974

Chiang, 1989

Dutta, 1989

Richter, 2000

Ivaschuk, 1999
Behari, 2006

Buchner, 2012

Kundi, 2009

Augner, 2009

Schwartz, 1990

Riddervold, 2008
Avendano, 2012

Novoselova, 1999

Tattersall, 2001

Yurekli, 2006
Stagg, 1997

Heinrich, 2010

Hutter, 2006

Khurana, 2010

Nittby, 2007

Hocking, 1996
Hocking, 2000

Kwee, 2001
Akoev, 2002

Stagg, 1997

Forgacs, 2006

Stankiewicz, 2006
Principal Investigator of Study, and Year of Publication

16
August 4, 2013 Ronald M. Powell, Ph.D.

FCC Maximum Permissible Exposure Limits for Electromagnetic

Radiation, as Applicable to Smart Meters
This document expresses my best understanding, as of the above date, of the FCC Maximum Permissible
Exposure (MPE) limits, as applicable to Smart Meters. This understanding has been reached by reading the
FCC document in the first footnote below, and by asking the FCC any questions that remained.

History
The FCC=s most recent explanation of its current exposure limits was published in 1999 with the title
"Questions and Answers about Biological Effects and Potential Hazards of Radiofrequency
Electromagnetic Fields".1 The current FCC exposure limits are based principally on a 1986 publication of
the National Council on Radiation Protection and Measurements (NCRP). That publication is AReport No.
086 - Biological Effects and Exposure Criteria for Radiofrequency Electromagnetic [email protected] The NCRP
was chartered by the U.S. Congress in 1964, but is not a Government agency and is not subject to oversight
by the Congress.3

The current FCC exposure limits agree, in part, with those developed jointly in 1992 by the American
National Standards Institute (ANSI) and the Institute of Electrical and Electronics Engineers (IEEE). The
exceptions are Alimits on exposure to power density above 1500 MHz, and limits for exposure to lower
frequency magnetic fields.@4 I will not address the ANSI and IEEE limits further here because the FCC
limits are the ones applicable to Smart Meters.

The fact that the current exposure limits are based on the NCRP limits published in 1986, now 27 years ago,

1
AQuestions and Answers about Biological Effects and Potential Hazards of Radiofrequency Electromagnetic
Fields@, OET (Office of Engineering and Technology) Bulletin 56, Fourth Edition, Federal Communications
Commission, August 1999.
( http://www.fcc.gov/Bureaus/Engineering_Technology/Documents/bulletins/oet56/oet56e4.pdf )
2
This document is sold by the NCRP for $56 in downloadable PDF form.
( http://www.ncrppublications.org/Reports/086 ).
3
The National Council on Radiation Protection and Measurements has this history: (1) in 1929, formed as the
U.S. Advisory Committee on X-Ray and Radium Protection; (2) in 1946, renamed as the National Committee on
Radiation Protection and Measurements; (3) in 1964, chartered by the U.S. Congress and renamed as the National
Council on Radiation Protection and Measurements.
( https://en.wikipedia.org/wiki/National_Council_on_Radiation_Protection_and_Measurements )
4
In the document in my footnote 1 above, footnote 9 on page 12 explains: >The FCC adopted limits for field
strength and power density that are based on Sections 17.4.1 and 17.4.2, and the time-averaging provisions of
Sections 17.4.1.1 and 17.4.3, of "Biological Effects and Exposure Criteria for Radiofrequency Electromagnetic
Fields," NCRP Report No. 86, for frequencies between 300 kHz and 100 GHz (Reference 34). With the exception of
limits on exposure to power density above 1500 MHz, and limits for exposure to lower frequency magnetic fields,
these MPE limits are also based on the guidelines developed by the IEEE and adopted by ANSI. See Section 4.1 of
ANSI/IEEE C95.1-1992, "Safety Levels with Respect to Human Exposure to Radio Frequency Electromagnetic
Fields, 3 kHz to 300 GHz".= Further, again in the document in my footnote 1 above, footnote 4 on page 10
describes ANSI and IEEE as follows: AANSI is a non-profit, privately funded, membership organization that
coordinates development of voluntary national standards. The IEEE is a non-profit technical and professional
engineering society.@

1
means that those limits: (1) predated the emergence of the vast majority of devices currently emitting
microwave radiation into our environment, including Smart Meters and other digital microwave devices;
and (2) cannot be current with results of medical research on the bioeffects of electromagnetic radiation,
including microwaves. The growth in the medical research literature since 1986 has been substantial and
is illustrated by the following figure. That figure shows the number of publications addressing AEMF@
(electromagnetic fields), as indexed in PubMed. PubMed is the on-line database of the medical research
literature maintained by the National Institutes of Health. PubMed is the most comprehensive index to the
medical research literature in the world.

Number of "EMF" Publications Per Year Listed by NIH's PubMed Database as of 8/4/2013
250

Nomber of "EMF" Publiccations Per Year

200

150

Year in which basis for current FCC Maximum

Permitted Exposure Levels was developed.
100

50

0
1946
1947
1949
1962
1964
1965
1966
1967
1968
1969
1970
1973
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
Year of Publication Ref: http://www.ncbi.nlm.nih.gov/pubmed/?term=emf

"EMF" Publications per Year Projected by author for 2013, as of 8/4/2013

On March 29, 2013, the FCC issued, for comment, proposed new exposure limits. While there are many
changes, the key numbers that are currently applicable to Smart Meters, as described in the next section,
appear to be unchanged. 5

Current FCC Maximum Permissible Exposure Limits

Within the FCC=s 1999 publication, AQuestions and Answers...@, the exposure limits of relevance to Smart
meters are contained in Table 1(B), entitled ALimits for General Population/Uncontrolled Exposure@, on
page 15. Since Smart Meters operate in two principal frequency bands, one at about 900 MHz, and one at
about 2400 MHz (which is equivalent to 2.4 GHz),6 just two lines from Table 1(B) apply to these frequency
5
Reassessment of Federal Communications Commission Radiofrequency Exposure Limits and Policies (ET
Docket No. 13-84), and Proposed Changes in the Commission's Rules Regarding Human Exposure to
Radiofrequency Electromagnetic Fields (ET Docket No. 03-137), released March 29, 2013. See Table 1 on pages
98, 110, and 122 of the PDF version. ( http://www.fcc.gov/document/fcc-review-rf-exposure-policies )
6
The FOCUS AXR-SD and the I-210+c both have FCC-ID OWS-NIC514, which indicates that they send and
receive information in two microwave frequency ranges: (1) 902.3 to 926.9 MHz, and (2) 2405.8 to 2480.9 MHz.
MHz means millions of hertz. 1 hertz is one cycle per second. The microwave output power in the first frequency
range is 0.968 watts. The microwave output power in the second frequency range is 0.147 watt. The sum of
these two is 1.115 watts. Landis+Gyr and PEPCO declined to answer a question as to whether the two frequency
ranges are used simultaneously. I assume that they are and have summed their outputs as a result
2
bands, as shown below.

Extracted from FCC Table 1 (B) Limits for General Population/Uncontrolled Exposure

line Frequency Range Power Density Averaging Time

MHz mW/cm2 minutes
(a) 300-1500 f/1500 30
(b) 1500-100,000 1.0 30
f is the frequency in MHz

Line (a) above applies to the 900 MHz frequency band used by Smart Meters. That line indicates that the
permitted power density increases as the frequency increases. At 900 MHz, the maximum permitted
power density is (900/1500) mW/cm2, which is 0.6 mW/cm2. Line (b) applies to the 2400 GHz frequency
band of Smart Meters, and the maximum permitted power density is 1 mW/cm2, independent of frequency.
With this understanding, Table 1(B) can be applied to Smart Meters, as shown below. I have added
columns that translate mW/cm2 into mW/m2 and into W/m2 for comparison with data from other sources.7

Limits for General Population/Uncontrolled Exposure for Smart Meters

Frequency Power Density Averaging Time

MHz mW/cm2 mW/m2 W/m2 minutes
900 0.6 6,000 6 30
2400 1.0 10,000 10 30

Interpretation of the Tables

Here is how to interpret the table. For easy reference, call the power-density levels in the table the
absolute levels, consistent with the terminology that the FCC uses.

(1) A continuous exposure of an individual is considered compliant with the FCC limits if that
exposure remains at or below the specified absolute level for that frequency, even if that exposure
continues indefinitely.

(2) A discontinuous exposure, such as that produced by a digital signal, is considered compliant with
the FCC limits, if the average exposure over a period of 30 minutes is at or below the specified
absolute level for that frequency. That is, if the exposure rises above the absolute level for that
frequency, even for a moment, then the average level, over a 30 minute period, must be at or below
the absolute level. Stated another way, periods of exposure at higher than the absolute level must

( http://stopsmartmeters.org/wp-content/uploads/2012/01/OWS-NIC514-FCC-specifications.pdf ).
7 2 2
1 meter (m) equals 100 centimeters (cm). So 1 square meter (m ) equals 10,000 square centimeters (cm ). 1
watt (W) equals 1000 milliwatts (mW).

3
 be accompanied, in any given 30 minute interval, by periods of exposure far enough below the
absolute level that the average over 30 minutes does not exceed the absolute level.

Because of (2) above, the level of exposure permitted for short intervals of time may greatly exceed the
absolute level. Consider an exposure that is ON for less than 30 minutes and the is OFF for the rest of the
30 minutes. Here are some specific patterns that would be permitted, no matter how many times the 30
minute pattern is repeated.

Examples of FCC Permitted Exposure Levels at 900 MHz

ON Time
ON Time OFF Time Fractions Permitted Power Density During ON Time
minutes:seconds minutes:seconds mW/cm2 mW/m2 W/m2
30:00 00:00 1 0.6 6,000 6
01:00 29:00 1/30 18 180,000 180
00:20 29:40 1/90 54 540,000 540
00:01 29:59 1/1800 1080 10,800,000 10,800

Examples of FCC Permitted Exposure Levels at 2400 MHz

ON Time
ON Time OFF Time Fractions Permitted Power Density During ON Time
minutes:seconds minutes:seconds mW/cm2 mW/m2 W/m2
30:00 00:00 1 1 10,000 10
01:00 29:00 1/30 30 300,000 300
00:20 29:40 1/90 90 900,000 900
00:01 29:59 1/1800 1800 18,000,000 18,000

Discussion of Examples of Permitted Exposure Levels

The surface area of a human being is about 2 m2.8 So the surface area presented to a microwave wave
coming from the front or the back is about 1 m2. Consider the W/m2 column in the above table. An
oncoming microwave wave will transfer to a human being the number of watts shown in the W/m2 column.
Consider the three examples at 2400 GHz that are contained in the preceding table:

(1) A microwave wave with a power density of 300 W/m2 will transfer 300 watts of power to a human
being. That is the amount of power required to run 3 light bulbs of 100 watts each. Such
8 2 2
The surface of a man is about 1.9 m . The surface of a woman is about 1.6 m . Both according to Wikipedia
( http://en.wikipedia.org/wiki/Body_surface_area )

4
 exposure would be compliant with the FCC exposure limits, if continued for 1 minute or less.

(2) A microwave wave with a power density of 900 W/m2 will transfer 900 watts of power to a human
being. This is somewhat more than the amount of microwave power, 700 watts, generated by the
typical consumer microwave oven.9 So exposure of a human being to a microwave wave with
somewhat greater power than a microwave oven would be compliant with the FCC exposure
limits, if continued for 20 seconds or less.

(3) A microwave wave with a power density of 18,000 W/m2 will transfer 18,000 watts of power to a
human being. This is between one-third and one-half of the maximum power that the typical
home can draw (48,000 watts) without tripping its master circuit breaker (200 amperes AC at 240
volts AC). Such exposure would be compliant with the FCC exposure limits, if continued for 1
second or less.

For each of the three examples given above, the level of exposure cited, with the associated duration, could
be repeated once each 30 minutes, indefinitely, and still be in compliance with the FCC exposure limits.

Finally, exposure of a human being at even higher power levels than discussed here is permitted by the FCC
exposure limits, if the duration of that exposure is sufficiently short.

These examples indicate that the current FCC exposure limits permit exposure levels to microwave
radiation that challenge common sense. While I have not yet read the 1986 NCRP publication on which
the current FCC exposure limits are based, I do wonder what sort of scientific basis I will find there that
could justify such extraordinary power levels, even in 1986.

Peak versus Average Exposure Levels

Given the above discussion, the concerns raised by the FCC exposure limits arise not only from high
permitted absolute levels, but also from the concept of time averaging, which does, indeed, seem based on
thermal thinking only. When the level of microwave radiation exposure is averaged over time, the implicit
assumption being made is that the body reacts the same way to:

(1) a burst of microwave radiation of high intensity but short duration

(2) a hypothetical continuous level of radiation at a lower level but with the same average value over
the same period of time

So a real burst-exposure event is translated into a hypothetical continuous exposure event, and the effect of
that hypothetical exposure event is taken to represent the effect of the real event. Yet, everyday life
suggests that the body may not react the same way to these two different circumstances. Ask a boxer if the
following two events are of equal concern: (1) a series of “average” punches over the length of a fight, or
(2) a single punch, somewhere during the fight, with the energy of the sum of all the “average” punches.

Thermal versus Non-Thermal Effects on Humans

The FCC developed two sets of exposure limits, one for Occupational/Controlled Exposure and one for the
General Population/Uncontrolled Exposure. Only the latter have been discussed here because only they

9
The typical consumer microwave oven consumes 1100 watts of electrical power and produces 700 watts of
microwave power. ( http://en.wikipedia.org/wiki/Microwave_oven )

5
apply to Smart Meters installed on residences. My understanding is that the Occupational set were based
principally on thermal (heating) effects on the human body; but the existence of possible non-thermal
effects was recognized back then, according to the FCC. So when the limits for the General Population
were developed, a factor of five reduction in permitted levels, relative to the Occupational set, was
implemented for the General Population set, for two reasons, again according to the FCC: (1) to allow for
non-thermal effects, and (2) to provide a safety margin because exposure levels in the General Population
would not generally be known as well as the levels in an occupational setting.

So the FCC exposure limits made some recognition of the existence of non-thermal effects. But I must
wonder if the knowledge of non-thermal effects, back in 1986, was adequate to support that factor of five.

Applying the FCC Exposure Limits

Additional information on applying the FCC exposure limits in contained in AEvaluating Compliance with
FCC Guidelines for Human Exposure to Radiofrequency Electromagnetic Fields@, OET Bulletin 65,
Edition 97-01, published in August 1997.10

Legal Presentation of the FCC Exposure Limits

The current FCC exposure limits are presented, in legal form, in the Code of Federal Regulations in 47 CFR
1.130711 and 47 CFR 1.1310.12 The latter publication is the one that contains Table 1 which also appears
in the FCC=s 1999 publication AQuestions and Answers...@ , OET Bulletin 56, introduced above.

10
( http://www.fcc.gov/Bureaus/Engineering_Technology/Documents/bulletins/oet65/oet65.pdf )
11
47 CFR 1.1307
( http://www.ecfr.gov/cgi-bin/retrieveECFR?gp=12&SID=049f730b665fd682e5a64add8d6b80b4&ty=HTML&h=L&r
=SECTION&n=47y1.0.1.1.2.9.192.7 )
12
47 CFR 1.1310
( http://www.ecfr.gov/cgi-bin/retrieveECFR?gp=12&SID=049f730b665fd682e5a64add8d6b80b4&ty=HTML&h=L&r
=SECTION&n=47y1.0.1.1.2.9.192.10 )

6
_____________________
Date

TO:
PEPCO Smart Grid Deferral
Mail Stop EP7642
701 9th Street NW
Washington, DC 20068

NOTICE OF DEFERRAL OF INSTALLATION OF SMART METERS PER PSC’S

ORDER NO. 84926 DATED MAY 24, 2012

I am hereby notifying PEPCO and its agents that you are not to install a Smart Meter
anywhere on my property pursuant to Order No. 84926 issued by the Maryland Public
Service Commission on May 24, 2012.

Because you have already installed a Smart Meter on my property, please remove that Smart
Meter and replace it with a –

TRADITIONAL ANALOG MECHANICAL METER

WITH NO WIRELESS COMMUNICATIONS CAPABILITY

Kindly send me a letter, acknowledging this letter, and then contact me, in advance of
coming, to set the date and the time that you will appear to make the requested replacement.

Thank you.

Regards,

______________________________
Signature

______________________________
Name (printed)

______________________________
Street Address

______________________________
City, State, and Zip Code

______________________________
PEPCO Account Number

______________________________
Telephone Number
 NOTICE TO
PEPCO AND
ITS AGENTS
PURSUANT TO ORDER
#84926 OF THE MARYLAND
PUBLIC SAFETY COMMISSION,
REPLACE THIS SMART METER

WITH A

TRADITIONAL ANALOG
MECHANICAL METER
WITH NO WIRELESS
TRANSMISSION CAPABILITY
 NOTICE TO
PEPCO AND
ITS AGENTS
PURSUANT TO ORDER
#84926 OF THE MARYLAND
PUBLIC SAFETY COMMISSION,
REPLACE THIS SMART METER

WITH A

TRADITIONAL ANALOG
MECHANICAL METER
WITH NO WIRELESS
TRANSMISSION CAPABILITY
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