In December 2013, the Massachusetts (MA) Department of Public Utilities (DPU) issued a document for comment entitled, “Investigation by the Department of Public Utilities on its own Motion into Modernization of the Electric Grid.”  The document contains “a straw proposal for moving forward with modernizing the electric grid.”  This proposal includes plans for utilization of “advanced metering” or smart meters.  Furthermore, the DPU document at one point makes the following statement:

• “Most grid modernization technologies involve the wireless transmission of data using radio frequencies (‘RF’).  Judging from other proceedings, it is possible that some electricity customers will question the effects of RF on their health.  A number of published reports on potential health effects of AMI suggest that RF from this technology is unlikely to harm health.”  [emphasis added]

In a footnote, the MA DPU then references three (3) documents to support the above claim:

•  World Health Organization, Systematic Review on the Health Effects of Exposure to Radiofrequency Electromagnetic Fields from Mobile Phone Base Stations (2010);

• Vermont Department of Public Service, An Evaluation of Radio Frequency Fields Produced by Smart Meters Deployed in Vermont (2013) (RF emissions from AMI fall well below the limits set by the Federal Communications Commission);

• Texas Public Utilities Commission, Health and RF EMF from Advanced Meters (2012) (“the large body of scientific research reveals no definite or proven biological effects from exposure to low-level RF signals”).

A welcome set of comments was submitted as part of the DPU docket by Donald R. Maisch PhD from Australia.  Dr. Maisch is a recognized expert on telecommunications standards and in the controversy that surrounds the level of health protection provided by the current internationally recognized RF exposure standards and guidelines.  What follows are excerpts from Dr. Maisch’s formal comments that urge halting the deployment of smart meters and casts doubt on the DPU’s assertion that the technology is unlikely to cause harm.

Three main points made by Dr. Maisch are:

1. “While the standard limits do provide protection against the known thermal effects (tissue heating from acute exposures) they are not relevant to the type of exposure people may receive from advanced metering infrastructure (AMI), hereafter referred to as smart meters.”

2. “… evidence … strongly indicates claims that all health effects from exposure to electromagnetic fields (power-frequency and radiofrequency) are just a nocebo effect are unjustified.  Given the large numbers of consistent health complaints coming from countries where smart meters have been rolled out, this represents a potential risk (cost) to the Massachusetts’ grid proposal, which currently is not being addressed.”

3. “The suggestive evidence that smart meter RF emissions may be having an adverse health impact calls for a research effort in order to quantify that risk.  Even if the number of affected people is small, the sheer number of people exposed represents a potentially significant public health risk.” … Regarding research:  “Most importantly, an independent oversight committee would be created and would include members from concerned community organizations, public interest groups and the medical fraternity.  This would ensure that the eventual findings have been obtained without the influence of vested interests.”

Dr. Maisch concludes that:

• “Taking a strictly benefit-cost analysis viewpoint, the cost of the public opposition to AMI (smart metering) technology, based on health concerns, is a factor that needs to be included in any such analysis.  Whether or not that factor is real of imagined is not the issue in this regard.  It exists and can only be resolved by independent research as outlined above.

• It is therefore recommended that the Massachusetts state government err on the side of caution and halt the deployment of AMI smart metering until the above-mentioned research has been conducted and the issue clarified.  Only then can steps be taken to eliminate or mitigate the risk once the extent of it is known.”  [emphasis added]

Finally, Dr. Maisch concludes his comments by examining the three (3) documents referenced by the MA DPU to support an assertion that smart meter technology is unlikely to “harm human health.”  Overall, he concludes that the first two references given in the Massachusetts DPU report (1 and 2 ), do have scientific merit but that the Texas report does not.  Dr. Maisch indicates that, in his opinion, the Texas report “should not have been included as a reference in the Massachusetts DPU electricity grid modernization report.”

1. “The referenced WHO report, titled Systematic review on the health effects of exposure to radiofrequency electromagnetic fields from mobile phone base stations, does not deal with smart meter exposures.  It concludes that no relationship exists between mobile phone base stations and acute symptom development (thermal effects).  However, for long-term effects it concludes ‘data are scarce and the evidence for the absence of long-term effects is limited.  Moreover, very little information on effects in children and adolescents is available and the question of potential risk for these age groups remains unresolved. Where data are scarce, the absence of evidence of harm should not necessarily be interpreted as evidence that no harm exists. Further research should focus on long-term effects and should include children and adolescents…. such studies should include an assessment of exposure to other sources of radiofrequency electromagnetic fields in daily life, such as mobile and cordless phones and wireless local area networks’.”

[SkyVision Solutions Added Commentary:  The 2010 WHO document is outdated since it was published prior to the WHO’s IARC declaration in 2011 that RF radiation is possibly  carcinogenic.]

2. “The report by Richard Tell Associates, titled An Evaluation of Radio Frequency Fields Produced by Smart Meters Deployed in Vermont, is a very informative report on actual smart meter measurements and is useful in that regard.  It concludes that any potential exposure to the investigated smart meters will comply with the FCC exposure rules by a wide margin.”

[SkyVision Solutions Added Commentary:  The Vermont document basically demonstrates that smart meter RF emissions comply with outdated FCC exposure guidelines.]

3. “The report, written for the Public Utilities Commission of Texas (PUCT), was prepared by Alan Rivaldo, a Cyber Security Analyst at PUCT.  Titled Health and RF EMF from Advanced Meters the report takes the extreme view that a scientific consensus has been reached within the body of scientific evidence for RF, and people who do not understand this are suffering from misconceptions based on faulty assumptions.  This supposed consensus according to Rivaldo is that there are no known non-thermal effects from exposure to RF.  He asserts that reports of EHS are unrelated to RF exposure but may be due to psychiatric conditions or stress from worry, going on to say that ‘scientific studies show that people who are ill are highly receptive to negative suggestions and may demonstrate a nocebo response as a result of these suggestions’. The overall impression given by the report is that the ‘weight of scientific evidence’, as presented by organizations such as the IEEE, ICNIRP, the FCC and others, is a body of credible research which is above serious reproach.  Any claims otherwise come from notorious, biased researchers who lack scientific rigor.  In what is unusual for a supposedly scientific document, the report resorts to making personal attacks on a number of people.  While serving up a diatribe against anyone claiming that non-thermal effects exist, especially about smart meters, the author altogether overlooks the significant industry biases and level of scientific uncertainty that exists in the RF controversy, relying exclusively on industry sources for his claims.  As such, the PUCT report reads more like the writings of a product defence PR company than a scientific review, which it is not.”

[SkyVision Solutions Added Commentary:  The smart meter health report released by the Public Utility Commission of Texas (PUCT) is nothing more than a propaganda document that parrots the sentiment of the smart grid industry.  It is not a peer-reviewed paper and merely reflects a compilation of biased commentary and quotations extracted from other industry prepared documents.  The author has no subject matter technical expertise, plus the document preparation was financially supported by a Department of Energy smart grid grant award.]

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Full Comments by Donald R. Maisch, PhD

Links for other Comments Submitted as Part of the MA DPU Docket:

Comments from the Massachusetts Association for the Chemically Injured (MACI)

Comments by David O. Carpenter, MD

Comments by Dr. Amy Dean

Comments from the EMR Policy Institute