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Feb 23

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Rebuttal Against Public Utility Commission of Texas Smart Meter Claims

It has come to our attention that the Public Utility Commission has released a document that is being distributed to power companies and their board members all over the state of Texas.  This prepared document entitled Project 40190, Project Relating to Advanced Metering Issues refutes all claims on potential health risks of radio frequency electromagnetic fields emitted by smart meters.  Supposedly, the PUCT staff has determined that the large body of scientific research reveals no definite or proven biological effects from exposure to low-RF signals; further, PUCT staff found no credible evidence to suggest that advanced meters harmful amounts of EMF.

The PUCT report was prepared by Alan Rivaldo, who lists himself as a Cyber Security Analyst at the PUCT.  His education is listed as an MBA from Rochester Institute of Technology.  One would have expected this analysis to be conducted by an electrical engineer, but it is merely a compilation of studies performed by other government agencies and the EPRI (a utility industry research group).  Two major thoughts about this report is he is a non-engineer, and there is most definitely a potential conflict of interest.

We have received communiques concerning this report from several engineers.  Below is a summary of their findings which directly contradict what Mr. Rivaldo has presented!

The executive summary spent a lot of time reviewing the criticisms levied against smart meters and their potential harmful effects.

Here are the mitigating factors listed from EPRI research, and my comments on why these may not always hold:

  1. The intensity of RF EMF is reduced exponentially with greater distance from the emitting device; – This is physics.  No dispute.
  2. The shielding provided by the meter enclosure; – Again, shielding reduces the intensity according to the rules of physics.  However, the quality of the shielding may vary from vendor to vendor and meter to meter.
  3. The home’s building materials further weaken the field strength; – This is totally dependent on the environment into which the meters are introduced and can vary widely.
  4. The meter antenna orientation inhibits the inward direction of the field pattern; – This is also dependent on the vendor and meter model.  Do manufacturers claim to have an antenna design that ensures the field pattern is oriented away from the structure?  Are installers instructed to mount the meters so that they have a pattern that faces away from the home?
  5. RF EMF emissions are only intermittent; a smart meter typically transmits 1-5% of the time. – Most disturbing is the fact that the homeowner has no say in how often the meter is transmitting.  While the claim is that it is 1-5%, they cannot prove that all meters are configured this way or stay configured this way.  This percentage may be for a properly functioning meter, and may be much higher for one that is malfunctioning.

Further, in the executive summary, the CCST report is cited.  It compared smart meters to other RF-emitting household devices.  What it failed to mention was that people chose to have all those other devices…they are not allowed to choose the smart meter.

I looked at Figure 3, and found it to be very misleading.  An average power density is not very helpful, since the note indicates that “the power density is average, not instantaneous”.  Without further explanation, it is hard to determine whether the graph is showing the 1% transmit power averaged over the 99% non-transmitting and 1% transmit time.  The instantaneous power density (when transmitting) is likely 100 times higher.

The main points about which the report is silent are these:

  1. All of this considers only properly or normally functioning devices.  If the devices can be commanded to transmit on a continuous duty cycle (100%), then the margin to the various exposure limits is greatly reduced.
  2. The effects appear to be treated in isolation.  The effects are cumulative, such that other emitters in the home contribute to reduce the margin to exposure limits.

As we discussed, the greater problem of smart meters is the information security problem and invasion of privacy.

The second engineer brings out a great point that none of the EMF studies that the PUCT is using have included the fact that humans are electrical beings themselves and the PUCT and other entities are not taking into account the routers, collectors, relays, tower antennas, that are major emitters of EMF.  The specific absorption rate didn’t include the bioelectricty of human beings and left out millions of frequencies in doing so.  Please see this document which discusses this in detail.

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