Dr. Li invited to provide his professional opinion concerning the safety of Smart Meters

Letter from Dr. De-Kun Li, MD, PhD, MPH   (De-Kun Li, MD, PhD, MPH, is a senior research scientist at the Division of Research, Kaiser Permanente Northern California).

Kaiser Permanente Division of Research 2000 Broadway Oakland,

CA 94612

Dear Ms. Martin:

Thank you for inviting me to provide my professional opinions on the

SmartMeter safety issue. I will address two questions raised in the attached

letter. But first, here is some background information:

1. Currently there are no national or international “standards” for safety

levels of radiofrequency (a range of 3 kHz to 300 GHz) devices. What FCC

is currently using are “guidelines” which have much lower certainty than a

“standard”. One can go to many governmental agencies’ websites like

NIOSH, EPA, FDA, etc. to verify this. Therefore, for anyone to claim that

they meet “FCC” standards gives a false impression of safety certainty

compared to “guidelines” which implies that a lot is “unknown.”

2. The current FCC “guideline” was adopted by FCC based on EPA’s

recommendation in 1996. EPA made the recommendation “with certain

reservation”. There was a letter by Norbert Hankin, Center for Science and

Risk Assessment, Radiation Protection Division at EPA describing the

current FCC guidelines (The letter can be found through a Google search).

According to Hankin’s letter, the FCC current guidelines were solely based

on “thermal effect” of radiofrequency, a level at which radiofrequency can

cause heat injury. As we know, heat injury is not what the public is

concerned about regarding radiofrequency safety. Their concerns are about

cancer, miscarriages, birth defects, low semen quality, autoimmune disease,

etc. Hankin’s letter, specifically emphasized that the EPA recommended

guidelines that FCC is currently using do not apply to non-thermal effects or

mechanisms (e.g., cancer, birth defects, miscarriage, autoimmune diseases,

etc) which are the focus of the public’s concern. Hankin’s letter states

Therefore, the generalization by many that the guidelines protect

human beings from harm by any or all mechanisms is not justified.”

3. In addition to being limited to only the thermal effect, the letter also states

that the current FCC guidelines recommended by EPA were only based on

experiments on animals in laboratories. Establishing firm safety standards

usually requires evidence from human studies such as epidemiological

studies. The current FCC guidelines were based on animal studies only, not

human data, which may explain why they are only considered as guidelines

rather than standards. Furthermore, the thermal effect, used to establish the

FCC guidelines, was based on acute thermal effect. It did not even deal with

chronic long-term intermittent effect. In fact, Hankin’s letter also states

exposures that comply with the FCC’s guidelines generally have been

presented as “safe” by many of the RF system operators and service

providers who must comply with them, even though there is uncertainty

about possible risk from nonthermal, intermittent exposures that may

continues for years”

4. Electromagnetic fields (EMFs) can come from sources with a spectrum of

frequencies. EMFs from electric power sources usually have a frequency

less than 1 kHz , while radiofrequency (RF) generated by SmartMeters are

reportedly in the range 900 MHz to 2.4 GHz. While overall research on the

EMF health effect remains limited, there are more reported studies

examining the EMF health effect in power line frequencies (< 1 kHz)

including some of my research1-3 than in RF. It is not clear at this moment

whether the findings on the EMF health effect at lower frequencies (i.e., < 1

kHz) can be applied to RF range. If the underlying mechanisms are similar,

the findings in lower frequency EMFs can then be applied to RF range for

SmartMeter. Many studies of power frequencies reported associations with

childhood leukemia, miscarriage, poor semen quality, autoimmune diseases

at a level much lower than those generating thermal damage as used by


5. Many chronic diseases that the public is concerned about (e.g., cancer)

have a long latency period and take decades to show symptoms. Most

wireless network and devices have only been used widely in the last 10 to 15

years. Therefore, many studies evaluating RF health effect related to cancer

risk previously, if they failed to identify an adverse health effect, are not

appropriate to be used as evidence to claim the safety of RF exposure since

the latency period has not been long enough to show the effect even if an

adverse association does indeed exist.

6. While the underlying mechanisms of the potential EMF health effect are

not totally understood at present, skeptics have been focused on the EMF

thermal effect, especially those who are NOT in the profession of

biomedical research, such as physicists. It is now known that EMFs can

interfere with the human body through multiple mechanisms. For example,

it has been demonstrated that communication between cells depends on

EMF signals, likely in a very low level. External EMFs could conceivably

interfere with normal cell communication, thus disrupting normal cell

differentiation and proliferation. Such disturbance could lead to miscarriage,

birth defects, and cancer.

To address the two questions raised in the letter:

1. Whether FCC standards for SmartMeter are sufficiently protective of

public health taking into account current exposure levels to radiofrequency

and electromagnetic fields. First, FCC currently has only “guidelines”, not

standards as explained above. Second, as described in the background

information above, the current FCC guidelines only deal with thermal effect,

which was also based on animal studies only. Meeting the current FCC

guidelines, in the best-case scenario, only means that one won’t have heat

damage from SmartMeter exposure. It says nothing about safety from the

risk of many chronic diseases that the public is most concerned about such

as cancer, miscarriage, birth defects, semen quality, autoimmune diseases,

etc. Therefore, when it comes to non-thermal effects of RF, which is the

most relevant effect for public concerns, FCC guidelines are irrelevant and

can not be used for any claims of SmartMeter safety unless we are

addressing heat damage.

2. Whether additional technology-specific standards are needed for

SmartMeter and other devices that are commonly found in and around

homes, to ensure adequate protection from adverse health effects. Safety

standards for RF exposure related to non-thermal effects are urgently needed

to protect the public from potential adverse health effects from RF exposure

that are increasingly prevalent in our daily life due to installation of everpowerful

wireless networks and devices like SmartMeter. Unfortunately

scientific research is still lacking in this area and some endpoints like cancer

take decades to study. The safety standards are not likely to be available

anytime soon. The bottom line is that the safety level for RF exposure

related to non-thermal effect is unknown at present and whoever claims that

their device is safe regarding non-thermal effect is either ignorant or


In summary, we do not currently have scientific data to determine where the

safe RF exposure level is regarding the non-thermal effect. Therefore, it

should be recognized that we are dealing with uncertainty now and most

likely for the foreseeable future. The question for governmental agencies,

especially those concerned with public health and safety, is that given the

uncertainty, should we err on the side of safety and take the precautionary

avoidance measures? Unknown does not mean safe. There are two unique

features regarding SmartMeter exposure. First, because of mandatory

installation, it is a universal exposure. Virtually every household is exposed.

Second, it is an involuntary exposure. The public that are exposed to

SmartMeters do not have any input in deciding whether they would like to

have the SmartMeter installed. The installation is imposed upon the public.

Governmental agencies for protecting public health and safety should be

much more vigilant towards involuntary environmental exposures because

governmental agencies are the only defense against such involuntary

exposure. Given the uncertainty of the SmartMeter safety, one rational first

step of public policy could be to require household consent before

installation of SmartMeters. Finally, because of the nature of universal

exposure, many susceptible and vulnerable populations including pregnant

women and young children are unknowingly exposed 24 hours a day, 7 days

a week. Usually, the threshold of harmful level is much lower for

susceptible populations.


1. Li DK, Odouli R, Wi S et al. A population-based prospective cohort

study of personal exposure to magnetic fields during pregnancy and the risk

of miscarriage. Epidemiology 2002;13(1):9-20.

2. Li DK, Yan B, Li Z et al. Exposure to magnetic fields and the risk of

poor sperm quality. Reprod Toxicol 2010;29(1):86-92.

3. Li DK, Checkoway H, Mueller BA. Electric blanket use during

pregnancy in relation to the risk of congenital urinary tract anomalies among

women with a history of subfertility. Epidemiol 1995;6:485-489.

De-Kun Li, MD, PhD, MPH, is a senior research scientist at the

Division of Research, Kaiser Permanente Northern California.

Dr. Li completed his medical training and master’s degree in public health at

Shanghai Medical University, Shanghai, China. He then received his PhD in

epidemiology from the University of Washington, Seattle. Dr. Li has conducted

research in the areas of pregnancy outcomes, sudden infant death syndrome,

women’s health, breast cancer, pharmacological effects on pregnancy outcomes,

genetic etiology, and occupational exposures since 1984. His research interests

include: reproductive, perinatal, and pediatric epidemiology, such as etiology of

miscarriage, sudden infant death syndrome, preterm delivery, preelcampsia, low

birth, infertility, cerebral palsy, birth defects, pediatric diseases (including

childhood cancer and neurological disorders), autoimmune diseases in relation to

maternal-fetal interaction, breast cancer, and risk factors for low semen quality.

Dr. Li’ research areas also include pharmacoepidemiolgical effect of medication

use during pregnancy, genetic determinants of adverse pregnancy outcomes, the

effect of electromagnetic fields on adverse pregnancy outcomes and low sperm

quality, and the effect of endocrine disruptors, specifically Bisphenol A (BPA), on

male and female reproductive systems. He is currently the associate editor of the

American Journal of Epidemiology. Dr. Li has participated in a National Institute

of Child Health and Human Development (NICHD) sponsored panel evaluation of

“Back to Sleep” campaign and Sudden Infant Death Syndrome risk. He has also

served as a member on the Ad Hoc Committee reviewing the NICHD program

project, and on several Special Emphasis Panels at National Institute of

Occupational Safety and Health and National Institute of Environmental Health

and Sciences reviewing grant proposals. He has served as a member of the

Policy Committee at the American College of Epidemiology. He was invited by

the National Academy of Science to participate as a panel member in the U.S.-

China Roundtable on Collaboration of Biomedical Research. In addition, he

teaches at Stanford University and supervises doctoral students from the

departments of epidemiology at UCB (University of California, Berkeley) and

UCLA (University of California, Los Angeles).

Dr. Li has published extensively with 29 first-authored publications. He has

obtained, as the principal investigator, numerous grants, ranging from $600,000

to $ 3.49 million from various federal agencies of the National Institutes of Health,

as well as the California Public Health Foundation. Many of his publications have

been widely reported by the national, international, and local news media

including recent studies of caffeine intake and miscarriage, pacifier use and use

of a fan in relation to SIDS risk, and depression during pregnancy and preterm

delivery. Other examples of work receiving wide media coverage include the risk

of miscarriage associated with EMF exposure, NSAID use and the risk of

miscarriage, hot tub use during pregnancy and the risk of miscarriage, and

maternal-fetal HLA compatibility and the risk of preterm delivery.

Current Position(s):

Research Scientist III, Division of Research, Kaiser Permanente Northern


Lecturer, Stanford University, Department of Health Research and Policy

Primary Research Interests:

Reproductive, prenatal, and pediatric epidemiology, such as etiology of infertility,

miscarriage, preterm delivery, preeclampsia, sudden infant death syndrome,

cerebral palsy, birth defects; pediatric diseases, including childhood cancer and

neurological disorders; autoimmune diseases in relation to maternal-fetal

interaction, and breast cancer.

Health effects of electromagnetic fields

Pharmacological effects of medication use during pregnancy on pregnancy


Genetic determinants of pregnancy outcome

Risk factors for poor semen quality

Health effect of endocrine disruptors, especially Bisphenol A (BPA), on male and

female reproductive systems


Attention All Texans Who Want An Anologue Meter! Please Read.

To: All Texans

Subject: The Smart Electric Meter

Date: September 1, 2014

This message is for you if you have any interest in having the smart meter on your home removed and replaced with an analog meter.

I will provide a little background information for your consideration.

The movement for a smart electric grid commenced several years ago while we paid no attention to what our representatives were doing. The ultimate goal is to establish one electric grid for the world.

At this time Texas has its own electric grid. The world grid would permit taking electric power from Texas and moving it to China if that is where power was needed. This is the purpose of the world grid.

The Texas legislature passed a bill to start the move toward the world grid. The Governor signed the bill and passed it to the Public Utilities Commission [3 commissioners appointed by the Governor] to enforce. The PUC is the enforcer of utilities laws. In the implantation of the smart grid law the PUC agreed with the electric providers to demand all users have the smart meter whereas the law said users should be encouraged to have the smart meter installed. Herein lays the problem we are faced with today. The PUC [unelected commissioners] have issued a rule with the force of law that demands that all users have the smart meter. A group of citizens have risen up against such tyranny and have succeeded in having the legislature tell the PUC to provide an opt-out for the smart meter. The PUC after many months has published such a rule. However the rule requires the user [customer] pay a large up front [one time] charge and the pay a monthly fee to not have the meter.  I ask you “What do you get for these funds”. My answer is NOTHING. You had the analog meter until the provider changed it and you’ve had you meter read by the provider from the first month of service. So why pay for the reading twice each month?

The PUC issued the opt-out rule without a public hearing the fact is they denied a public hearing request by citizens of Texas.

The citizens group has filed an appeal in court asking the court to force the PUC to hold a public hearing. There are issues that to date the PUC has refused to hear. The public hearing will allow the citizens their day in court.

We encourage you to join us in fighting for our rights. Information on our appeal was written by Thelma Taomina and I placed it below for you to read.

Please plan to attend to help. Please let me know if you can help us.

John Tweedell

Texans Against Smart Meters

Message below is from: Thelma Taormina

On December 2, 2014 an appeal that has been filed with the Travis County Court will be heard.  The complaint filed is regarding a denial by the Public Utility Commission of Texas for a Full Public Hearing on the issue of Advanced Meters (aka Smart Meters).

The appeal is asking for the Judge to order the PUC of TX to order a Full Public Hearing on the “Proposed Rule(s)” initiated by 193 Texans.  The PUC of TX wrongly denied the citizens of TX a full public hearing regarding concerns over the privacy concerns and health issues relating to the smart meters.

At this first court appearance we will be asking the Judge to order the PUC of TX to follow not only the laws in TX, but also the PUC’s own rules as set up by the Commission.

We are asking individuals to please attend this court hearing to impress upon the Judge that it is not only a handful of Texans who are concerned about the smart meters and the issues raised concerning privacy and health.  The more people who attend the hearing will prove to the Judge and all in attendance that Texans are seriously concerned about this issue.

If there is any possibility that you can attend, please show up at  Herman Marion Sweatt, Travis County Courthouse, 1000 Guadalupe, Austin, TX 78701 on December 2, 2014 at 2:00 PM.