Center for Electrosmog Prevention CEP Expanded Opt-Out Proposal

Presented to ALJ Amy C. Yip-Kikugawa, California Public Regulatory Commission August 18, 2011

Introduction Center for Electrosmog Prevention proposes protective measures in its broad-based opt-out plan, designed to protect the public from rf radiation and other emissions caused through use of wireless smart meters. These include an immediate, science-based1, no-cost opt-out to analog meters; protections including a smart-meter-free-zone; removal of all banks of wireless meters; progressing to removal of all wireless meters and infrastructure from the smart grid; with full public disclosure. CEP requests no-cost customer choices that utilize the Precautionary Principle, apply current, independent science, and protect the public health. CEPs Smart Meter Opt-Out Proposal Overview IMMEDIATE RELIEFREMOVE ALL WIRELESS, IMPROVE SAFETY & STANDARDS ------ALL CALIFORNIA UTILITIES SHALL BE ORDERED TO DO THE FOLLOWING, AT NO COST TO CONSUMERS: ------IMMEDIATE REMOVAL OF: WIRELESS2 METERS TO PROTECT MEDICALLY VULNERABLE / MEDICAL OR OTHER COMPLAINANTS W/200 FOOT WIRELESSFREE ZONE ALL BANKS OF WIRELESS METERS RETURN ALL TO NO-COST ANALOGS

------REMOVE ALL: WIRELESS COMPONENTS FROM HOMES, RESIDENCES, BUSINESSES

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See attached scientist letters with both opt-out and wireless removal solutions mentioned. Wireless meters shall be defined here as those with the capability of transmitting or receiving, whether this mechanism is switched on or off.

Center for Electrosmog Prevention CEP Expanded Opt-Out Proposal

Presented to ALJ Amy C. Yip-Kikugawa, California Public Regulatory Commission August 18, 2011

WIRELESS INFRASTRUCTURE FROM SMART GRID

------AT NO COST TO CONSUMER, USE ANALOGS FOR SAFETY NOW MANDATE UTILITIES TO ALLOW MULTIPLE, NO-COST, NONWIRELESS OPTIONS FOR CONSUMERS SUCH AS ANALOG AND IN THE FUTURE, EXPLORE OFFERING CHOICES SUCH AS WIRED M-POWER METERS* IF THESE DO NOT RECEIVE, TRANSMIT, OR PRODUCE HARMFUL EMISSIONS, INCLUDING DIRTY ELECTRICITY, ELEVATED ELECTROMAGNETIC FIELDS, RF RADIATION, OR OTHER POTENTIAL ENVIRONMENTAL HAZARDS, UTILIZING THE PRECAUTIONARY PRINCIPLE. (*FOLLOWING INDEPENDENT STUDY) PROVIDE FULL DISCLOSURE TO THE PUBLIC ABOUT POSSIBLE RF RADIATION BIOLOGICAL OR HEALTH EFFECTS PER CURRENT INDEPENDENT SCIENCE SMART METERS WITH TRANSMITTERS TURNED OFF ARE NOT ACCEPTABLE, AS THIS WILL NOT REDUCE THE INCOMPATIBILITY WITH HOME WIRING AND PRODUCTION OF DIRTY ELECTRICITY EMISSIONS. CEP requests that CPUC implement the following Opt-out Measures for SDG&E and all other utilities in CA. These are practical, vital requests to reinstitute the health and safety of
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Center for Electrosmog Prevention CEP Expanded Opt-Out Proposal

Presented to ALJ Amy C. Yip-Kikugawa, California Public Regulatory Commission August 18, 2011

Californians, extrapolated from the advisement of world health authorities, based on thousands of scientific studies. These measures are reasonable solutions that will allow immediate protection of the most sensitive sectors of the public, followed swiftly by protection of the entire general public. The citizens of California should not have to pay for mistakes such as the wireless smart meter program whose architects ignored science and proceeded even when health effects were pouring in by the thousands. It is CEPs position that smart meters with transmitters turned off are an unacceptable choice.

CEP requests that CPUC and utilities provide immediate relief and protections for the public as follows: Immediate Relief: 1. Pay particular attention to person complaining of any medical issues or exacerbations of medical issues following installation of wireless smart meters, intolerance to radiation and/or electromagnetic fields, or medical concerns about installed or planned installations of smart meters, and introduce special measures to immediately protect them. We suggest that the following be immediately adopted: a. All utility customers in the state of California who have any concerns about smart meters are to be offered an immediate, no-cost change out to and use of a traditional analog meter within 7 days.

Center for Electrosmog Prevention CEP Expanded Opt-Out Proposal

Presented to ALJ Amy C. Yip-Kikugawa, California Public Regulatory Commission August 18, 2011

b. All utility customers in the state of California with a concern about smart meters shall be granted the ability to keep their analog meters, if they have not yet received a smart meter. c. Utility customers who opt-out shall be afforded a no-cost 200 foot nowireless smart meter perimeter from their residences. d. Group no-cost, analog opt-outs are to be allowed, including condo associations, residential communities, and any type of municipality. 2. Banks of smart meters in planned developments, apartment, commercial or residential groupings or condo units will be immediately removed and replaced with analog meters, as the combined emissions are a greater risk for all and cannot be reduced adequately for sensitive individuals who request opt-outs. 3. The utility will also remove all wireless collector meters immediately and replace them with analog meters. The utility will be ordered to remove all additional antennas around the State that are part of the smart grid system within 30 days. 4. The CPUC should order an immediate halt to data received or sent by automatic meter readers and requires all current smart meters be immediately disabled from transmitting or receiving data. No underground or above ground wireless transmission signals of any kind shall be allowed for any power, gas, or water utilities throughout the State.

Center for Electrosmog Prevention CEP Expanded Opt-Out Proposal

Presented to ALJ Amy C. Yip-Kikugawa, California Public Regulatory Commission August 18, 2011

5.

CPUC should order an immediate and permanent halt on any plans to increase the rate or number of transmissions or signal strength in any smart meter as this may compound health and safety problems.

6. Issuance by CPUC of an immediate moratorium on the installation of all types of automatic and/or wireless metering devices, including but not limited to smart meters, by any utilities in California. 7. CPUC adopts policy forbidding the promotion or use of wireless technologies for all utilities and regulatees. Replacement and Costs of Smart Meters in General: 1. A no-cost replacement of automatic metering devices/smart meters to analog meters within 2 months for all customers, to protect the public health and welfare of humans, pets, animals, insect populations, wildlife and the environment. This will be done at no cost to the customer; as the ratepayers should not be held responsible for the costs of either implementing or mitigating this dangerous smart meter plan that did not take into consideration the thousands of available studies and scientific warnings available. 2. Full disclosure shall be made of all the costs incurred by the utilities, to date, for the removal of analog meters and replacement by smart meters, also the subsequent removal and replacement of smart meters with analog meters, so that customers will not be charged for these individually or as a whole.

Center for Electrosmog Prevention CEP Expanded Opt-Out Proposal

Presented to ALJ Amy C. Yip-Kikugawa, California Public Regulatory Commission August 18, 2011

3. Cost to the utilities shall not be reduced through use of smart meters with transmitters turned off, as this shall not satisfy the goal of no emissions and this would require the trust of members of the general public, which has been damaged.

Disclosure: 1. Establish public information and awareness-raising campaigns within 30 days and continue on an on-going basis on the risks of all possible harmful long-term health or biological effects [from electromagnetic fields] on the environment and on human health, pets, animals, insect populations wildlife, or the environment as determined by independent researchers, scientists, and experts in the field of electromagnetic radiation and in particular RF radiation. These campaigns should especially target all possible effects of electromagnetic radiation on children, teenagers and young people of reproductive age. Content of notification to be approved by CEP and associates. 2. The public shall be notified in billing statements and media, of the full range of complaints about wireless smart meters, with content of notification to be approved by CEP and associates. 3. Full disclosure by the utility for smart grid deployment efforts and/or plans for smart meters uses, in totality, for all uses planned or to be planned in the future including but not limited to collector meters, locations of antennas, signal strength, distribution(s) of data to marketing firms, and any planned changes, in easy to understand language for review and approval by the general public.

Center for Electrosmog Prevention CEP Expanded Opt-Out Proposal

Presented to ALJ Amy C. Yip-Kikugawa, California Public Regulatory Commission August 18, 2011

4. All utilities must publish within 30 days all of the functional specifications of the meters now being installed, including their block diagrams, schematics, or bill of materials. The scientific community has been prevented from identifying any of the design problems prior to their installations. Utilities must also provide smart meters to any researcher who wants to investigate the possible damage to human, pets, animals, insect populations, and wildlife that may have already occurred. 5. All utility customers be notified of the possibility of fire and explosions from smart meters and afforded the opportunity for immediate no-cost change out and use of a traditional analog meter if they encounter appliance losses, humming, or intermittent power outages. Overall Needs: 1. The CPUC and all utilities will use the precautionary safety principle risk assessments that are prevention orientated when implementing current or future services and/or making any decisions regarding changes to those services. Now, and at no time in the future, shall any utility deliver services in a manner that places the health or safety of the public, the environment, wildlife, vulnerable populations, pets, animals, or insect populations at risk. As a result, CPUC should utilize rigorous and independent health, safety and environmental impact studies that will base recommendations on the Precautionary Principle, without fail, for all current and future endeavors. This risk-assessment will be accomplished by creating a standard risk scale that will pay heed to and protect early warning scientists and making the indication of the risk level mandatory, commissioning several risk hypotheses and
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Center for Electrosmog Prevention CEP Expanded Opt-Out Proposal

Presented to ALJ Amy C. Yip-Kikugawa, California Public Regulatory Commission August 18, 2011

considering compatibility with real life conditions. This strategy will promote pluralistic and contradictory debates between all stakeholders prior to adopting new technologies so that future adoptions will not result in costly mistakes that will net higher energy costs for the State of California. 2. An immediate end to utility monopolies in each geographical area by the CPUC establishing competing utilities so that there is a choice for healthy and green alternatives that are not harmful to humans, wildlife, animals, or the environment, etc. per independent experts and scientists in the field with no conflicts of interest, authorized and approved by interested CPUC applicants/parties who are smart grid objectors (parties), paid for by CPUC. 3. No utility company in California will be allowed to pollute the indoor or outdoor environments by increasing exposure to electromagnetic fields or any type of radiation (aka contributing to electrosmog). Natural background levels for electromagnetic fields and radiation shall be maintained at all times throughout the State, as determined by independent authoritative sources and scientific evidence. FCC standards, which are obsolete, based on 1993 and prior scientific information, shall not be utilized as the measure of safety for rf radiation exposures (see attached FCC letter to CCST). 4. Appliance manufacturers shall be prohibited from using wireless technology in the State of California that can communicate with any source inside the home or outside of the home in which the appliance is located.

Center for Electrosmog Prevention CEP Expanded Opt-Out Proposal

Presented to ALJ Amy C. Yip-Kikugawa, California Public Regulatory Commission August 18, 2011

5.

No alternative to the smart meter that may be incompatible with older wiring or appliances shall be utilized, including wired options. Analog meters shall be the only option for all consumers, for public health and safety reasons.

6. If, at some time in the future, fiber optic or cable transmission options are considered, the full impact on health and safety shall be studied extensively by independent, impartial researchers, paid for by CPUC and all results made public before any further planning takes place. In order to reduce costs, save energy, and protect the environment and human health, step up independent research on new types of antennas and wireless devices, and encourage research to develop devices based on other technologies which are just as efficient but have less negative effects on the environment and health. 7. Independent citizen oversight panel approved by parties (or their designees) with no personal or other conflicts of interest, tasked with Precautionary Principle safety protections as its primary goal, and paid for by CPUC to oversee all of these areas. 8. The expertise and commentary of the following experts shall be taken into consideration and their suggestions shall be directly applied to solutions: please note attachments commentary of authoritative public health organizations, scientists on rf radiation, smart meters, and health, such as the following: Authoritative Public Health organizations: WHO, CA Dept of Health (Kreutzer, Rudolph); scientists: Lai, Havas, Hirsch; Physician/Public Health experts: Carpenter, Johansson, Maret, Plumlee, Milham, Neutra; and Environmental Consultants who have independently studied smart meters: Sage. These include the immediate relief recommended by these authorities, provided by non-wireless, analog opt9

Center for Electrosmog Prevention CEP Expanded Opt-Out Proposal

Presented to ALJ Amy C. Yip-Kikugawa, California Public Regulatory Commission August 18, 2011

outs and removal of wireless technologies from the smart grid, with use of fiberoptic, shielded cable and/or phone lines, utilizing independent environmental health and safety testing before implementation, with full protection of the public utilizing the Precautionary Principle not basing safety on obsolete FCC guidelines which were never intended to protect from smart meters, per these experts.

Suggested Scope of the Opt-Out Workshop Sept 14th, 2011: 1. CPUC ALJ consider all opt-out options / proposals and enter each one of these proposals into the public record. 2. CPUC ALJ consider criteria for opt-outs. 3. CPUC ALJ consider cost issues of opt-outs. 4. CPUC / ALJ provides citation and selected text of all federal and state laws and CPUC / federal policies or guidelines that apply to smart grid technologies related to wireless and smart meters as the standard. Laws cited by Parties and non-parties be entered into the record pertaining to required or suggested smart grid technologies, to clarify legalities.

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Center for Electrosmog Prevention CEP Expanded Opt-Out Proposal

Presented to ALJ Amy C. Yip-Kikugawa, California Public Regulatory Commission August 18, 2011

5. CPUC ALJ consider and issue appropriate, immediate emergency opt-out measures to provide relief for Californians with medical complaints related to smart meter installations and for those who wish protection from potential health effects. 6. The workshop should address the specific reasons for requiring an Opt-Out Workshop (that led to this). Solutions cannot be found for a problem that cannot be discussed or spoken, as they are intrinsically and irrefutably related. For instance, the information on health effects are relevant to the Smart Grid proposals and the Opt-Out proceeding, and must be included, as this is a primary reason for opt-out discussions and public concern. a. CPUC and utilities present a complete compilation and summary of all studies and reports of any kind related to health and safety of smart meters, rf emissions, and electromagnetic fields commissioned or reviewed by utility companies and the CPUC during the development and implementation period of the smart meter project. b. Allow Parties to have the option to present expert letters and a compilation and/or summaries of all studies and reports related to health and safety of smart meters, rf emissions, and electromagnetic fields, to be entered into the public record. c. Obsolete standards (such as FCCs rf radiation standard) shall not be utilized, nor shall the reports of industry-biased groups, their affiliates, or

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Center for Electrosmog Prevention CEP Expanded Opt-Out Proposal

Presented to ALJ Amy C. Yip-Kikugawa, California Public Regulatory Commission August 18, 2011

those who conduct business with the architects or funders of the smart grid, such as US DOE. 7. CPUC and utilities present a complete, sorted data set of all California consumer smart meter complainants to utilities and the CPUC, including but not limited to those with health complaints. Complainants to be sorted by type of complaint (health etc.), number of complaints per consumer, and dates of complaint(s). 8. Utilities present complete data sets and summary of comparisons on cost of analog meters and transmitter-off smart meters when read by a meter reader, as well as analog meters vs. smart meters using both wireless and wired transmissions.

Susan Brinchman, Director Center for Electrosmog Prevention PO Box 655, La Mesa, CA 91944 director@electrosmogprevention.org

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