comment: center for safer wireless testimony, case 9207 and 9208

7/31/2019 Comment: Center for Safer Wireless Testimony, Case 9207 and 9208

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Cases 9207 and 9208

Center for Safer Wireless * P.O. Box 166 * Haymarket, Virginia 20168 *U.S.A.* 703-431-1558

www.centerforsaferwireless.org

April 5, 2012

David J. Collins

Executive Secretary

Maryland Public Service Commission

William Donald Schaefer Tower

6 St. Paul Street, 16th Floor

Baltimore, MD 21202

Re: Maryland Public Service Commission Request for Comments

Case No. 9207 Potomac Electric Power Company and Delmarva Power and Light Company Request

For Deployment of Advanced Meter Infrastructure

Case No. 9208 - Baltimore Gas and Electric Company - In the Matter of the Authorization to Deploy a

Smart Grid Initiative and to Establish a Surcharge Mechanism for the Recovery of Costs

Dear Mr. Collins:

Thank you for the opportunity to provide written comments on whether the Maryland Public

Service Commission should require the subject utilities to offer customers the opportunity to opt

out of receiving a smart meter (Case 9207 and Case 9208). The Center for Safer Wireless is a 501

(c)(3) national nonprofit organization that improves public understanding of wireless products and

technology

Its interesting that this hearing is scheduled since Section 1252 Smart Metering of the US Energy

Policy Act of 2005 states Each electric utility subject to subparagraph (A) shall provide each

customer requesting a time-based rate (bolding added) with a time-based meter capable of

enabling the utility and customer to offer and receive such rate, respectively. Have Pepco

customers requested smart meters? On the frequently asked questions section of the Pepco

website, question 3.7 is Can I keep my current meter? Pepcos answer is No. Pepco is authorized

by the Maryland Public Service Commission to remove its current meters and install our smart

meters for all of its Maryland customers. I wonder if this is a true statement since I found no

statement in Maryland Public Service Commission orders involving Cases 9207 and 9208 that smart

meters are mandatory in Maryland.

The Center for Safer Wireless supports a program to allow customers to retain their analog meters

in Maryland because smart meters pose the following concerns:

1. Privacy and security risks2. Health risks


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Cases 9207 and 9208 Maryland Public Service Commission Comments

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3. Interference and fire risks4. Questionable energy savings

Introduction

The installation of smart meters on homes will create a wireless mesh of microwave radiation as

home area networks are added in dwellings. After residents purchase new appliances with smart

chips, their exposure to microwave radiation in the home will substantially increase. The smart

chips will record what time the appliance was used, how long it was used, and what time the use

ended. It will wirelessly send the data to the homes smart meter. Visualize a spider-web of

microwave transmissions as data moves throughout the home from televisions sets, stereos, home

entertainment systems, telephones, computers, printers, dishwashers, washer and dryers,

dishwashers, refrigerators, microwave ovens, toasters, hair dryers, electric tooth brushes etc to the

smart meter. In addition, there is another layer of microwave transmissions to residents as one

smart meter communicates with the next door neighbors smart meter and the next smart meter.The wireless communication continues until the data reaches a collector meter, wherein the data is

transmitted to the utility via a cell tower.

As reported by the San Diego Gas and Electric Company (SDGE) in response to a request from an

Administrative Judge, smart meters installed by SDGE transmit messages on average 1270 times

per day and at a maximum 25,920 times each day.1 Pacific Gas and Electric reported that up to

190,000 messages can be communicated via one smart meter in only 24 hours. 2

Privacy Concerns

Smart meters raise privacy concerns. According to a February 2012 Congressional Research Service

Report entitledSmart Meter: Privacy and Cybersecurity, the Department of Energy reported that by

matching data with known appliance load signatures, smart meters will be able to reveal peoples

daily schedules, their appliances and electronic equipment, and whether they use certain types of

medical equipment. 3 Utilities will have the data to discern the behavior of occupants in their home

over a period of time. This mandatory device on our homes will track more private information

than a GPS affixed to a criminals car, even though the US Supreme Court Case recently determined

that a warrant was needed in the GPS case.

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

2. Ann and Chonda J. Nwamu, Pacific Gas and Electric Law Department, PACIFIC GAS AND ELECTRIC COMPANYS RESPONSE TOADMINISTRATIVE LAW JUDGES OCTOBER 18, 2011 RULING, DIRECTING IT TO FILE CLARIFYING RADIO FREQUENCY

INFORMATION, November 1, 2011, page 5.3 Murrill, Brandon J., Liu, Edward C., and Thompson, Richard M., Smart Meter Data: Privacy and Cybersecurity, Congressional Research Service,February 3, 2012. Page 4.
http://www.centerforsaferwireless.org/documents/CongressResearchServiceSMprivacyandcybersecurity.pdfhttp://www.centerforsaferwireless.org/documents/CongressResearchServiceSMprivacyandcybersecurity.pdfhttp://www.centerforsaferwireless.org/documents/CongressResearchServiceSMprivacyandcybersecurity.pdfhttp://www.centerforsaferwireless.org/documents/CongressResearchServiceSMprivacyandcybersecurity.pdf


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The Electronic Privacy Information Center cites a list of potential privacy consequences of Smart

Grid Systems including, identity theft, activity censorship, profiling, tracking behavior of

renters/leasers, and real-time surveillance.

In a recent radio interview on NPRs Fresh Air, John Villasenior at the Brookings Institution revealed

that beginning May 2012, US federal agencies, such as law enforcement, will be able to use small

undetectabledrones to monitor US citizens. These drones can intercept wireless communications

coming from smart meters, Wi-Fi, or cell phones. 4 While US citizens can choose wired Internet

connections and landlines to limit their surveillance vulnerability, Maryland residents currently

cannot turn off or opt out of smart meters; thus they are vulnerable to drone monitoring.

Utilities claim they wont sell the data they will store, even though the information is a marketing

pot of gold. Well seeRegardless, in the fall of 2015, companies will be permitted to operate

drones and third parties will easily access a wealth of information about private behavior in our

homes thanks to wireless smart meters.5

Wireless smart meters also pose security concerns. Television shows and media accounts have

revealed threats from hacking and terrorism to the smart grid. These concerns are also

documented by the Department of Homeland Security and the National Security Agency. Former

CIA Director James Woolsey accounted the wireless security threat at

http://www.metacafe.com/watch/4260978/jim_woolsey_grid_security_is_afterthought/ More

cybersecurity information is outlined in theCongressional Research Report, Smart Meter Data:

Privacy and Cybersecurity.

Health Concerns

Independent scientists and engineers have for many years expressed their deep concerns about the

inadequacy of the current FCC (Federal Communications Commission) radiofrequency radiation

human exposure guidelines. These guidelines are thermally-based and only warrant protection for

the public for up to 30 minutes, and workers for up to 6 minutes at a time. Since pulsed

radiofrequency radiation from wireless smart meters emit non-thermal radiation 24 hours a day,

seven days a week, many experts believe the FCC guidelines are not sufficiently protecting the

health and safety of the public against the chronic, low level, and cumulative exposure conditions

people are now being exposed too.

In February 2011, the International Electromagnetic Fields Alliance announced theSeletun

Statement, a report published by international scientists that urges governments to follow

4 Drones Over America: What Can They See, National Public Radios Fresh Air Show, March 12, 2012http://www.npr.org/2012/03/12/148293470/drones-over-america-what-can-they-see

5 Ibid, Drones Over America: What Can They See?
http://www.metacafe.com/watch/4260978/jim_woolsey_grid_security_is_afterthought/http://www.metacafe.com/watch/4260978/jim_woolsey_grid_security_is_afterthought/http://www.centerforsaferwireless.org/documents/CongressResearchServiceSMprivacyandcybersecurity.pdfhttp://www.centerforsaferwireless.org/documents/CongressResearchServiceSMprivacyandcybersecurity.pdfhttp://www.centerforsaferwireless.org/documents/CongressResearchServiceSMprivacyandcybersecurity.pdfhttp://www.centerforsaferwireless.org/documents/CongressResearchServiceSMprivacyandcybersecurity.pdfhttp://www.iemfa.org/index.php/publications/seletun-resolutionhttp://www.iemfa.org/index.php/publications/seletun-resolutionhttp://www.iemfa.org/index.php/publications/seletun-resolutionhttp://www.iemfa.org/index.php/publications/seletun-resolutionhttp://www.npr.org/2012/03/12/148293470/drones-over-america-what-can-they-seehttp://www.npr.org/2012/03/12/148293470/drones-over-america-what-can-they-seehttp://www.npr.org/2012/03/12/148293470/drones-over-america-what-can-they-seehttp://www.iemfa.org/index.php/publications/seletun-resolutionhttp://www.iemfa.org/index.php/publications/seletun-resolutionhttp://www.centerforsaferwireless.org/documents/CongressResearchServiceSMprivacyandcybersecurity.pdfhttp://www.centerforsaferwireless.org/documents/CongressResearchServiceSMprivacyandcybersecurity.pdfhttp://www.metacafe.com/watch/4260978/jim_woolsey_grid_security_is_afterthought/


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significantly lower human exposure standards for electromagnetic fields. Based on power density

measurements, the Scientific Panel found sufficient evidence that adverse health effects exist at as

low as 0.17 mW/ m. This amount is approximately 50,000 60,000 times lower than the current

ICNIRP/FCC standards.

Smart meters have caused health problems throughout the US. In May 2011, the World Health

Organization determined that radiofrequency electromagnetic fields emitted from wireless devices

are a class 2B possible human carcinogen, in the same class as lead, DDT, and chloroform. The

American Academy of Environmental Medicine opposes the installation of wireless smart meters

based on the current medical literature. People across the United States with AMI smart meters on

their homes are reporting ringing in the ears, insomnia, strong headaches, nausea, heart

palpitations, memory loss, anxiety and pain which began occurring after smart meters were

installed. Some people are electrosensitive and cant tolerate any form of pulsed radiofrequency

radiation. You can read individuals reports about the health effects of smart meters at

http://emfsafetynetwork.org/?page_id=2292.

Since smart meters are a new technology, there is no scientific literature about the health risks of

these devices. But in a memo about smart meters from Poki Stewart Namkung, M.D. Health Officer

at the Santa Cruz Health Services Agency to the Santa Cruz County Board of Supervisors, Dr.

Namkung stated, evidence is accumulating on the results of exposure to RF at non-thermal levels

including increased permeability of the blood-brain barrier in the head (Eberhardt 2008), harmful

effects on sperm, double strand breaks in DNA which could lead to cancer genesis (Phillips, 2011),

stress gene activation indicating an exposure to a toxin (Blank, 2011), and alterations in brain

glucose metabolism (Volkow, 2011). There are more scientific studies noted in the Appendix.

Wireless smart meters are capable of interfering with implanted medical devices.According to Gary

R. Olhoeft, SBEE and SMEE (MIT) and Ph.D. (Physics, University of Toronto), and current Professor

of Geophysics at Colorado School of Mines, smart meters can interfere with sensitive medical

implants such as deep brain stimulators for Parkinsons disease and pacemakers. He has

experienced this type of interference and set up his home to minimize RF exposure. During a Black

Hat security conference in August 2011, a security researcher who has diabetes demonstrated on

stage how a third party can transmit wireless commands to remotely disable his insulin pump. The

pump accepted and followed commands from any wireless source.

Interference, Billing, and Fire Concerns

Smart meters interfere with a variety of household wireless gadgets such as garage door openers,

Wi-Fi, security systems, cordless phones, wireless headsets, patio speakers, and baby monitors as

reported in California and Maine. For example, the Maine Public Advocates office announced on

November 19 that smart meters installed by Central Maine Power are causing interference with a
http://emfsafetynetwork.org/?page_id=2292http://emfsafetynetwork.org/?page_id=2292http://www.emrpolicy.org/regulation/united_states/7jan2011_doj_ada_olhoeft_comment.pdfhttp://www.emrpolicy.org/regulation/united_states/7jan2011_doj_ada_olhoeft_comment.pdfhttp://www.emrpolicy.org/regulation/united_states/7jan2011_doj_ada_olhoeft_comment.pdfhttp://www.emrpolicy.org/regulation/united_states/7jan2011_doj_ada_olhoeft_comment.pdfhttp://www.emrpolicy.org/regulation/united_states/7jan2011_doj_ada_olhoeft_comment.pdfhttp://www.emrpolicy.org/regulation/united_states/7jan2011_doj_ada_olhoeft_comment.pdfhttp://emfsafetynetwork.org/?page_id=2292


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wide range of wireless devices in the home, such as garage door openers, electric fences, Wi-Fi,

and security systems. http://www.pressherald.com/news/electronics-on-the-fritz_-could-be-

smart-meters_2011-11-19.html

Improper installation of or faulty smart meters have lead to fires, inaccurate billing, and damages.

These stories have been reported in California, Florida, Virginia and Texas.http://www.wfaa.com/news/Fires-Spark-During-Smart-Meter-Installations-101115429.html

http://www.click2houston.com/news/28147128/detail.html

http://www.zacks.com/research/get_news.php?id=123e2577

http://emfsafetynetwork.org/?p=4904

Questionable Energy Savings

While utilities claim energy savings from smart meters, the Connecticut Office of Attorney General

issued a letter on February 8, 2011 indicating no overall decreased energy usage in a pilot test with

smart meters as compared to existing analog meters. A similar study covering one year of smart

meter usage in England came to the same conclusion.

We believe that an opt-out program should include a provision enabling utility customers to retain

analog meters at no additional cost, as long as customers communicate their electric meter

readings to utilities once a month. It can be as easy as taking a picture of the analog meter and

emailing it to the power company. The service structure for analog meters is already in place, so itcan be maintained in the future.

The costs of operation of the wireless infrastructure such as the increased demand for electricity to

power the wireless meters, educational campaigns, and smart meter installations will be spread

across all ratepayers, i.e., those with wireless meters and those who choose to keep their current

meters. The cost for retaining a current meter should be treated the same way.

Of significant concern is that opt out fees in California, Nevada, and Maine are at least in part

designed to deter those who are considering opting out. The fees should not be intended to

discourage ratepayers from choosing to keep their current meter. It is inappropriate that an opt-out fee becomes a de facto deterrent to making that choice, especially for low-income ratepayers

whose health and well being may be adversely impacted by a wireless meter. In Maine, Ed

Friedman has filed a case arguing that ratepayers who retain their analog meters should not pay

initial or additional monthly utility fees.
http://www.pressherald.com/news/electronics-on-the-fritz_-could-be-smart-meters_2011-11-19.htmlhttp://www.pressherald.com/news/electronics-on-the-fritz_-could-be-smart-meters_2011-11-19.htmlhttp://www.pressherald.com/news/electronics-on-the-fritz_-could-be-smart-meters_2011-11-19.htmlhttp://www.pressherald.com/news/electronics-on-the-fritz_-could-be-smart-meters_2011-11-19.htmlhttp://www.pressherald.com/news/electronics-on-the-fritz_-could-be-smart-meters_2011-11-19.html


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Please preserve the individual rights of your ratepayers. By allowing customers to retain their

analog meters at no additional cost, you will uphold our founding fathers principals of individual

rights. Please join the states of California, Nevada, and Maine by permitting a smart meter opt-out

program and improve on those programs by ordering utilities not to charge additional costs to

ratepayers retaining their analog meters in Maryland.

Thank you for the opportunity to share my views on this important topic.

Sincerely,

Christine M. Hoch

Executive Director


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Appendix Citing Scientific Studies and Policy Statements

Radiofrequency (RF) radiation and health impacts

WHO International Agency for Research on Cancer (IARC) classifies Radiofrequency-

Electromagnetic Fields as a 2B (Possible) Human Carcinogen (5/31/11)

www.iarc.fr/en/media-centre/pr/2011/pdfs/pr208_E.pdf

This is the same kind of RF-EMF as smart meters produce and at equivalent levels to those

on which the IARC finding was made.

Scientific studies and policy statements on links between exposure to RF radiation and health

impacts:

Seletun Scientific Statement published in Reviews on Environmental Health 2010 Oct-

Dec;25(4):307-17. This report published by a consortium of international scientists urges

global governments to adopt significantly lower human exposure standards for

electromagnetic fields. The recommendations are based on the latest body of evidence in

biological sciences, and the public health implications of the unprecedented global

exposures to electromagnetic fields from telecommunications and electric power

technologies. Text at: http://international-emf-alliance.org/index.php/publications/seletun-

resolution

PathophysiologyElectromagnetic Fields (EMF) Special Issue Volume 16, Issues 2-3, Pages 67-

250 (August 2009) http://www.sciencedirect.com/science/journal/09284680/16/2-3 From

the Preface to this Special Issue:

This special issue of Pathophysiology includes scientific papers on the EMF issue by contributors to

the BioInitiative Report, as well as others, and is prepared for scientists who are not specialists in

bioelectromagnetics.

Effects of RF Radiation on Human Health and Disease. Non-thermal biological effects of RF

radiation exist and occur at doses previously thought to be safe. Thermal effects alone

should not be considered an acceptable readout of biological effects.

http://tinyurl.com/7yqhh3p


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Changes of Clinically Important Neurotransmitters under the Influence of Modulated RF

Fields. http://www.buildingbiology.ca/pdf/rimbachstudy.pdf

Nerve Cell Damage in Mammalian Brain after Exposure to Microwaves from GSM MobilePhones.

http://ehp03.niehs.nih.gov/article/fetchArticle.action?articleURI=info%3Adoi%2F10.1289%

2Fehp.6039#abstract0

In Sweden, electrohypersensitivity (EHS) is an officially fully-recognized functional

impairment http://iopscience.iop.org/1755-1315/10/1/012005

Listing of studies of studies which demonstrate a nexus between EMF and adverse health

impacts and/or the development of thermal or non-thermal effects which may lead to

health problems http://www.heartmdinstitute.com/wireless-safety/scientific-research

Parliamentary Assembly of the Council of Europe (PACE) policy statement regarding dangers

of RF radiation to humans

http://assembly.coe.int/Main.asp?link=/Documents/AdoptedText/ta11/ERES1815.htm


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Certificate of Service

I, Christine M. Hoch, hereby certify that an original and 17 copies of these comments from the Center for

Safer Wireless regarding case 9207 and 9208 were sent via overnight mail on Thursday, April 5, 2012 to

David J. Collins, Executive Secretary, Maryland Public Service Commission, William Donald Schaefer Tower

6 St. Paul Street, 16

th

Floor, Baltimore, MD 21202

_________________________ _______

Christine M. Hoch 4/5/12