(Sept. 25, 2012) Maine PUC Meeting
Today, Maine’s Public Utility Commissioners, for the time being, turned down a request by Spain-owned CMP, the state’s largest utility company, to accept the FCC’s RF radiation emission “standards” as applying to smart meters.
(Sept. 25, 2012) Maine CPUC Meeting
Commissioner Littell stated, ” They [CMP] ask us [in a Motion] to rule as a matter of law that the FCC’s RF radiation standards apply to smart meters. Those emission standards are set for mobile devices. They are not necessarily set for other devices, though that is an issue in this case. So I think that is an evidentiary issue as well as a legal issue which we have already been hearing some argument on and we’ll be seeing evidence on, so I think it would not be appropriate at this juncture. I don’t see a clear legal argument. So I think that would be my suggestion, subject to Commissioner Vannoy.
Commissioner Vannoy: “I would agree with you, Commissioner Littell. I don’t find this pre-empted on this case. I also would look at the question, “is the commission standard at the heart of the case as far as the evidence that is brought forth through the course of the case and we’ll look forward to that portion of the case.”
Commissioner Littell: So to be fair, we’ll expect to see arguments on those issues and decided in the case, and that said, we look forward to the Parties expeditiously proceeding. And one last point, I would note is that CMP, in its Motion, suggested that we take a look at one of their filings. We haven’t done that. So, we haven’t had time to do that, among other issues. So we haven’t considered any additional evidence in making any of the evidentiary filings that have been made primarily in CMP’s case. I just want to make that clear on the record.”
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The Commissioners went on to consolidate a new 10-Person Complaint focused on opt out fees, with the existing investigation proceeding. The new complaint raised timely issues not addressed in the current case, according to a source.
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CEP Notes: FCC has RF guidelines, not standards. These were developed using industry research, based exclusively on heating, several decades ago, and have not been changed since. Smart meters were not invented then. [1]
More info on the background of the FCC guidelines for RF radiation found at A Primer on FCC Guidelines for the Smart Meter Age.
Do FCC RF Guidelines Cover Smart Meters?
Smart Meters: unregulated, unsafe…
(EMF Safety Network, April, 2011)
In a recent Federal Communications Commission (FCC) letter to Congresswoman Lynn Woolsey, Julias Knapp, the FCC Chief of Office of Engineering and Technology, responds to an inquiry from the EMF Safety Network. The letter downplays the need for FCC oversight and regulation of their own installation RF safety conditions stating, “The grants of equipment authorization routinely list the four conditions cited by EMF [Safety Network] for the broad class of transmitters that include most Smart Meters….adherence to those conditions is not necessarily required for Smart Meters to achieve compliance with our RF exposure guidelines….the utility is responsible for ensuring compliance with any installation conditions listed on the grant of equipment authorization .”
In addition the FCC falsely claims, “the devices normally transmit for less than one second a few times a day and consumers are normally tens of feet or more from the meter face…”
FCC Grant of Equipment Authorizations: OWS-NIC514, OWS-NIC507, and LLB6327PWM (from PG&E Smart Meters Violate FCC RF Safety Conditions) Silver Spring Network’s RF module for utility [smart] meters – requires a separation distance of 20 cm. and no “co-location” with other antenna or transmitters, that the company is responsible for providing integrators and installers with safe installation, info re: safe operating conditions, and RF safety compliance.
FCC Part 15 Regulations “UNDERSTANDING THE FCC REGULATIONS FOR LOW-POWER, NON-LICENSED TRANSMITTERS” (1996)
FCC Part 15 Radio Frequency Devices: Subpart C “Intentional Radiators” (referred to as applicable to smart meters in OWS-NIC507)
Definition: “(o) Intentional radiator. A device that intentionally generates and emits radio frequency energy by radiation or induction.”(p. 4)
“Subpart C—Intentional Radiators
15.201 Equipment authorization requirement.
15.202 Certified operating frequency range.
15.203 Antenna requirement.
15.204 External radio frequency power amplifiers
and antenna modifications.
15.205 Restricted bands of operation.
15.207 Conducted limits.
15.209 Radiated emission limits; general requirements.
15.211 Tunnel radio systems.
15.212 Modular transmitters.
15.213 Cable locating equipment.
15.214 Cordless telephones.
RADIATED EMISSION LIMITS, ADDITIONAL
PROVISIONS
15.215 Additional provisions to the general
radiated emission limitations.
15.216 Disclosure requirements for wireless
microphones and other low power auxiliary
stations capable of operating in the
core TV bands.
[Operation in these applicable and other bands are as follows]:
15.243 Operation in the band 890–940 MHz.
15.247 Operation within the bands 902–928
MHz, 2400–2483.5 MHz, and 5725–5850 MHz.
15.249 Operation within the bands 902–928
MHz, 2400–2483.5 MHz, 5725–5875 MHz, and
24.0–24.25 GHz.”
Description within OWS-NIC507 [ Silver Spring ‘Smart’ Meter Module Equipment Authorization]: OWSNIC-507
Granted 3/20/2009
Equipment Class: Part 15 Spread Spectrum Transmitter
Notes: Electric Meter Radio Module
Modular Type: Limited Single Module
(Frequency) Range: 902.3 – 926.9 MHz
(Frequency) Range: 2405.8 – 2480.9 MHz
FCC Limits:
FCC Public Safety Limits (Sage)
FCC Violations Involving Smart Meters:
‘Smart’ Meters Violate FCC Regulations – Period. (a video that proves this)
PG&E Smart Meters Violate FCC RF Safety Conditions
From “Science for the Decision-makers and the Public” (Sage):
“FCC compliance violations are likely to occur under normal conditions of installation and operation of smart meters and collector meters in California. Violations of FCC safety limits for uncontrolled public access are identified at distances within 6” of the meter. Exposure to the face is possible at this distance, in violation of the time-weighted average safety limits (Tables 10-11). FCC violations are predicted to occur at 60% reflection (OET Equation 10 and 100% reflection (OET Equation 6) factors*, both used in FCC OET 65 formulas for such calculations for time-weighted average limits. Peak power limits are not violated at the 6” distance (looking at the meter) but can be at 3” from the meter, if it is touched.
This report has also assessed the potential for FCC violations based on two examples of RF exposures in a typical residence. RF levels have been calculated at distances of 11” (to represent a nursery or bedroom with a crib or bed against a wall opposite one or more meters); and at 28” (to represent a kitchen work space with one or more meters installed on the kitchen wall).
FCC compliance violations are identified at 11” in a nursery or bedroom setting using Equation 10* of the FCC OET 65 regulations (Tables 12-13). These violations are predicted to occur where there are multiple smart meters, or one collector meter, or one collector meter mounted together with several smart meters.
FCC compliance violations are not predicted at 28” in the kitchen work space for 60% or for 100% reflection calculations. Violations of FCC public safety limits are predicted for higher reflection factors of 1000% and 2000%, which are not a part of FCC OET 65 formulas, but are included here to allow for situations where site-specific conditions (highly reflective environments, for example, galley-type kitchens with many highly reflective stainless steel or other metallic surfaces) may be warranted.*
In addition to exceeding FCC public safety limits under some conditions of installation and operation, smart meters can produce excessively elevated RF exposures, depending on where they are installed. With respect to absolute RF exposure levels predicted for occupied space within dwellings, or outside areas like patios, gardens and walk-ways, RF levels are predicted to be substantially elevated within a few feet to within a few tens of feet from the meter(s).” [read more…]
1. FCC Policy on Human Exposure to Radiofrequency Electromagnetic Fields, http://transition.fcc.gov/oet/rfsafety/
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