FOR THE PUBLIC RECORD
Presented to the Jackson County Board of Commissioners
August 22, 2018
RF Health and Safety Research
2018 Science Summary
By Ed Kellogg, Ph.D.*
A Short Historical Overview
Beginning in the 1940’s, the biological effects of Radio Frequency (RF) microwave radiation became a concern after radar workers reported harmful effects, which included headaches, internal bleeding, heart conditions, brain tumors, and cataracts. Military scientists promoted the theory that since microwave radiation does not have enough energy to cause ionization (like X-rays do), only exposures that caused significant heating could have biological effects, and that safety tests for non-thermal (no heating) RF exposure levels seemed unnecessary.1 While many scientists accepted this idea, by 1996 enough evidence had accumulated to the contrary that in setting their maximum exposure standard, the FCC made it clear that this only applied only to the thermal effects of higher RF exposures. As Dr. Andrew Marino (a respected scientist with over 40 years’ experience in the area of EMF research) testified in his capacity as an expert witness to the Pennsylvania Public Utility Commission: “. . . the FCC defines an emission level as ‘safe’ if it doesn’t result in adverse biological effects caused by cooking or heating of the exposed subject.
Nowhere does the FCC say that smart meters are safe with regard to physiological changes caused by physical processes other than cooking or heating.” (p 44)2 In 1996 the FCC basically rubber-stamped the U.S. military standard set during the Cold War, when radar served a vital role in national defense, and when the health and long-term well-being of civilians from RF exposure did not seem a consideration. In contrast, many other countries—such as China, Russia, Italy, France, and Switzerland—have set maximum RF exposure limits one hundred to one thousand times less than the FCC “safe” level, which in 2018 has become the highest in the world.3 Other countries lowered their maximum RF exposure levels because they took into account thousands of research studies published in peer reviewed scientific journals that demonstrated that low-level microwave exposures had biological effects and could cause harm.4 Not surprisingly, given the severe financial consequences of updating the FCC safety standard downward to bring it into alignment with current scientific research, RF dependent technological industries, just as the tobacco industry did before them, have done their best to muddy the science, obscure the facts, and prevent regulatory change. But this task has become increasingly difficult over the past five years, now that large-scale studies have clearly demonstrated harmful effects of microwave exposures well below the 1996 FCC safety limit. Recent Landmark Radio Frequency Microwave Studies In 2016 the U.S. National Toxicology Program (NTP) released the results of a long term, large scale, $25 million-dollar study5 that clearly demonstrated that RF exposures—at frequencies emitted by devices such as cell phones and smart meters—caused both cancer and DNA breaks in animals at levels below the FCC’s “safe” exposure limit. In 2018, a panel of government appointed experts who reviewed these results concluded that the studies showed clear evidence of carcinogenic activity.6 Also in 2018 Italy’s Ramazzini Institute published a similar large-scale multimillion dollar study that replicated the NTP results with regard to cancer and DNA breaks, but at much lower levels of RF exposure.7 The Ramazzini study concluded: “The RI findings on far field exposure to RFR are consistent with and reinforce the results of the NTP study on near field exposure, as both reported an increase in the incidence of tumors of the brain and heart
in RFR-exposed Sprague-Dawley rats. These tumors are of the same histotype of those observed in some epidemiological studies on cell phone users. These experimental studies provide sufficient evidence to call for the re-evaluation of IARC conclusions regarding the carcinogenic potential of RFR in humans.”
Other important replicated effects, observed in many different laboratories at very low levels of RF exposure,4 include neurological damage in animals such as leakage of the blood brain barrier.8,9 Unfortunately, research has clearly established that children absorb far more RF radiation than adults, especially in the brain, making them much more vulnerable to harm.10 And obvious problems resulting from this harm may not show up immediately, but as with tobacco smoking, may take decades to appear.
As the authors of a 2012 review of RF blood brain barrier studies observed, “… neuronal damage may not have immediately demonstrable consequences, even if repeated. It may, however, in the long run, result in reduced brain reserve capacity that might be unveiled by other later neuronal disease or even the wear and tear of ageing. We can not exclude that after some decades of (often), daily use, a whole generation of users, may suffer negative effects such as autoimmune and neuro-degenerative diseases maybe already in their middle age.” (p 45) 9
However, we may not need to wait decades to see effects.
Neurological problems from RF exposure may have already shown up in two of the most vulnerable groups: In school age children, the Centers for Disease Control and Prevention has reported an alarming and increasing prevalence of autism.11 In teenagers, depression and suicides have increased, an increase that correlates with how much time teenagers spend with RF emitting devices such as cell phones and computers. 12
And according to the CDC even in the general population, suicide has recently increased at an alarming rate—rising over 25% across the United States from 1999 to 2016, with more than half of these suicides having no known mental health condition.13 And while correlation does not prove causation, these problems have increased roughly in synch with modern society’s exponentially increasing exposure to RF radiation, and make sense with respect to the neurological damage shown to occur in animals exposed to RF at these levels.4-9
Smart Meter Radio Frequency Microwave Emissions The Oregon Public Utility Commission (OPUC) and Pacific Power claim that smart meters cannot cause harm because the average microwave radiation emitted by them falls below the 1996 FCC maximum “safe” exposure limit. As we have documented here, decades of solid scientific research demonstrating low-level RF biological effects below that limit makes it clear that the FCC safety limit guarantees no such thing. How much RF do smart meters send out? According to Michael Dougherty, Chief Operating Officer of Oregon Public Utility Commission, the “smart meters Pacific Power is using are well within the Radio Frequency (RF) exposure limits established by the Federal Communication Commission (FCC). Pacific Power’s smart meters will transmit on average about 60 milliseconds every 15 minutes, which comes to about 60 seconds per day. The RF emissions of Pacific Power’s meter is about 1.6 percent of the maximum permissible exposure as determined by the FCC.”14 For the record, even 1.6% of the FCC limit exceeds or greatly exceeds the safe RF exposure limits in many other countries, such as China, Russia, Italy, France, Poland, Hungary, Switzerland, Belgium, and Austria.3
According to the Silver Spring Networks Whitepaper on Radio Frequency Emissions,15 provided by Pacific Power, the average power output of wireless laptops and smart meters seem about the same. However, while laptop emissions seem roughly continuous, smart meters send out intermittent, very short, high energy pulses about 1000 times stronger than the average RF power of a WIFI laptop.15,16
And while recent scientific research shows that even the low-level WIFI emitted from laptops has harmful effects,17 other research indicates that exposure to pulsed RF will have a potentially greater, and more biologically disruptive, effect. From Dr. Marino’s testimony before the Pennsylvania Public Utility Commission: “Based on previous studies regarding how human beings and animals detect man-made electromagnetic energy, we expected that pulsed energy would be more effective than non-pulsed energy in producing symptomatic responses,18 and that was what we observed and reported in the provocation study. Smart meters emit pulsed energy.” (p 25)2
And since the RF power unit of a smart meter has twice the wattage of a cell phone,19 and can easily send signals 45 miles or more, comparing its
emissions to the RF from a WIFI laptop, which can barely send a signal a hundred feet or so, bends the truth well past the breaking point.
Furthermore, when one actually goes to the source of the information used by Silver Springs and Pacific Power to reference their claims on smart meter RF output, the California Council on Science and Technology 2011 Report, “Health Impacts of Radio Frequency Smart Meters”,20 it becomes clear that they grossly misrepresent the data. Pacific Power compares for example, the maximum RF output of a cell phone held to the ear, to the output of a smart meter on a 50% duty cycle from 35 feet away.20,31 But according to the report itself, if one compares the instantaneous RF power density of a WIFI Router at 3 feet to that of a smart meter on a 50% duty cycle at the same distance, a smart meter sends out 20 to 100 times as much RF. (Fig. 1, p 6)
And as far as the FCC safety limit goes, even the OPUC’s 1.6% estimate grossly understates the potential worst-case RF output for smart meters, which from 1 foot away range from a minimum of 3% of the FCC “safe” exposure limit to maximum of 60%, depending on the duty cycle. (Fig. 5, p 20) And it bears repeating that the FCC “safe” exposure level for RF far exceeds the RF safety standards of many other countries by one hundred to one thousand times.3
Worse, both the OPUC and Pacific Power deliberately underestimate the impact of smart meters even more in another way, because they base their exposure estimates on an idealized best-case scenario for the RF output of a single model smart meter under unrealistic and idealized conditions.19,21 In actual operation, smart meters compete with one another as a group when sending transmissions, using a “frequency hopping radio signals dynamic,” and in crowded locations such as cities or apartment complexes on average will need to send signals many times, not just once, before they make it through.19
Furthermore, because smart meters operate on a mesh network, meters that cannot contact Pacific Power’s collector because of blockage, interference, or distance, pass their data (via frequency hopping and packets) on to a neighboring smart meter.22,23 This process continues until the data finally reaches a “downstream” meter that can contact and send this mass of data to PP’s collector, and will transmit many times more often than a smart meter sending only its own data.
So how many RF transmissions, and for how long, do smart meters actually broadcast each day? Pacific Power basically makes the same claims about
smart meters that PG&E used to, that they only transmit a few times a day, until a court order forced PG&E to disclose the truth.24 According to Table 2-1 in this document, as an average, smart meters did not transmit short high intensity RF bursts a mere 6 times a day as PG&E claimed, but because of the mesh network component, about 10,000 times a day.
And some smart meters actually send out many times more transmissions than that. In fact, one out of a thousand of those “downstream” smart meters which serve as final transmission points sends out over 190,000 transmissions a day, 875 seconds a day, 20 times the average.
But even this still does not describe a worst-case scenario. Bedrooms in some apartment complexes have not one, but a bank of as many as ten smart meters mounted outside a wall close to where residents sleep, all of them sending short but very intense RF signals several times a minute, 24 hours a day, 7 days a week. And some of these bedrooms have children in them, who absorb far more RF radiation than adults, especially in the brain, making them much more vulnerable to harm.10
On another front, as presently designed, when transmitting smart meters will also introduce RF frequencies throughout the electrical wiring of a house, creating High-Frequency Voltage Transients (HVFT)—popularly known as “dirty electricity” (DE).19 Although in a few epidemiological studies people have reported harmful effects from exposures to HVFT, scientific research has yet to confirm this, not because of the absence of such effects, but because of the absence of any controlled experimental studies, or funding for such studies, looking into the effects of DE at all.25
The OPUC has a duty to insure the safety of smart meters not just for a best-case RF exposure scenario, or for an “average” scenario, but for worst case scenarios, something it has clearly failed to do. This becomes especially important, now that we know that the microwave frequencies emitted by smart meters can cause cancer and DNA breaks,6-7 and because no one has
yet specifically looked into the biological effects of the intermittent, very short, high energy RF pulses emitted by smart meters,2 which research indicates may have much stronger and more disruptive effects than non-pulsed EMF.18 By failing to insure the safety of these devices the OPUC has in effect approved the use of human beings, especially low-income human beings who cannot afford the opt out fees, as guinea pigs.
Who Can We Trust?
In a letter responding to the Jackson County Board of Commissioners, Megan Decker, Chair of the Oregon Public Utility Commission wrote: “Regarding safety, the PUC has relied on numerous reports and findings from industry leaders that show that smart meter frequency (RF) technology is very safe.”26—which exactly sums up the problem. To get accurate information about the dangers of tobacco smoking, one would not ask the tobacco industry. Nor would one reasonably expect to obtain truthful information about the contribution of fossil fuels to climate change from the petroleum industry, the dangers of drugs from the pharmaceutical industry, and so on.
Historically, each of these industries has deliberately and repeatedly done their best to mislead and intentionally deceive the public and influence government policy for the sake of profit, despite the cost to human health. If recent corporate history has taught us anything, it should have taught us that we cannot rely on getting accurate and unbiased information about potential health and safety problems for a product from an industry that makes a profit by selling it. Instead, one must bring in the testimony of qualified, independent scientific experts who have no history of industry ties or other conflicts of interest. And this, by its own admission, the Oregon PUC has failed to do.
Furthermore, although corporate interests would have us believe otherwise, “absence of evidence” (no studies funded or published specifically on smart meter safety), and “evidence of absence” (published studies demonstrating the absence of a harmful effect of smart meters), do not seem the same thing.
Utility companies and smart meter manufacturers make the claim of safety not because of controlled scientific studies demonstrating the safety of smart meters—none at present exist2—but because the average (not maximum) RF output of smart meters falls below an outdated 1996 FCC RF exposure limit based on a disproven theory.1,27,28 And it seems important to note that
in 2018 the New Mexico Public Regulation Commission, which allowed testimony from independent scientific experts in the field (such as Dr. Paul Dart of Eugene Oregon,29) came to a very different decision than the Oregon PUC: The New Mexico PRC rejected a proposed installation of smart meters, concluding that “The Plan presented in the Application does not provide a net public benefit and it does not promote the public interest.” 30
On its website, Pacific Power falsely claims that “These radio waves have been proven to be safe and aren’t associated with any negative health effects, according to the FCC, the Electric Power Research Institute and the World Health Organization.”31
None of the organizations cited by Pacific Power—despite having a very strong industry bias in their expert panels32—have ever made the claim that “radio waves have been proven to be safe.” For example, let’s look at what WHO actually does say on its website, in a statement made in 2006:
“Based on a recent in-depth review of the scientific literature, the WHO concluded that current evidence does not confirm the existence of any health consequences from exposure to low level electromagnetic fields. However, some gaps in knowledge about biological effects exist and need further research.”33
Rather than strongly affirming the safety of low-level EMF, in this statement WHO’s panel of experts simply state that it could neither confirm—nor deny—the safety or harmfulness of exposure to low level electromagnetic fields. In essence, one can sum up this carefully spun policy statement as “At this time we don’t know, and we admit the need for further research.” And as we have documented here, compelling scientific research has appeared since WHO made that statement in 2006 demonstrating that low-level RF can cause harm.4-9
If one cannot rely on industry sources or the FCC as credible authorities on the issue of the potential adverse health effects of low level RF exposure, who can one trust? I’d look to The BioInitiative Group, an experienced group of independent scientists, who meticulously compiled a database of the biological effects of very low-level EMF and RF exposures, and who published “The BioInitiative 2012 Report” as well as a number of updates.27 Its authors include three former presidents and five full members of the Bioelectromagnetics Society (BEMS), the Chair of the Russian National Committee on Non-Ionizing Radiation, and a Senior Advisor to the European Environmental Agency.
A short excerpt from the conclusions of that report: “Bioeffects are clearly established and occur at very low levels of exposure to electromagnetic fields and radiofrequency radiation. Bioeffects can occur in the first few minutes at levels associated with cell and cordless phone use. Bioeffects can also occur from just minutes of exposure to mobile phone masts (cell towers), WI-FI, and wireless utility ‘smart’ meters that produce whole-body exposure. Chronic base station level exposures can result in illness.” With respect to safety, given the potential for harm, a new drug has to undergo a rigorous set of controlled scientific studies and tests before making it to market. Unfortunately, although RF exposure also clearly has the potential to harm, safety testing has only begun to take place on the wide variety and frequencies of microwave radiation saturating the modern environment. And each year new and also untested kinds of microwaves—like the RF emitted by smart meters, and soon 5G—get added to the mix. Given the now established fact that low-level microwave exposures do have biological effects, and can cause harm in animals4-9,27, it makes sense that one should approach the public roll out of any RF emitting device including the smart meter with a certain degree of caution, beginning with the funding of a wide range of safety studies, before exposing the public to this kind of potential risk.
Instead, the situation has become almost unbelievably bizarre.
In 2016, in his Expert Testimony before the Pennsylvania Public Utility Commission, Dr. Andrew Marino described the situation with respect to the smart meter roll out by the Philadelphia Electric Company (PECO) as follows:
“PECO is intentionally exposing human subjects to the electromagnetic energy from smart meters, which is something that cannot be done by any research institution in the United States without first securing permission and consent within the context of federal laws. The upshot is a Kafkaesque situation in which bona fide investigators cannot study the risks of smart-meter electromagnetic energy unless they follow stringent rules, especially the rule involving consent, and yet PECO can involuntarily expose human subjects in the absence of any oversight whatsoever.” (p 34)2
The same, of course, applies to the current roll-out of smart meters by Pacific Power here in Oregon and in Northern California.
When pressed, even industry scientists will admit that there exists a great deal of scientific research on both sides of the issue of whether low-level RF radiation causes harm—with industry funded scientists mostly on one side, and industry independent scientists on the other, but with all research done by credentialed, respected scientists.33,34
In most situations like this, where legitimate scientific controversy exists over a potential environmental hazard, the precautionary principle would have come into play many years ago. It hasn’t. Instead of the government requiring industry to demonstrate the safety of smart meters through peer reviewed research studies, customers suffering ill effects with scant resources and no scientific expertise find themselves forced to go to court to try to prove that smart meters can cause harm.2
The fact that low level microwave exposures can cause DNA breakage and cancer in animals4-7 does not actually seem the most important point. Instead, one must understand that the simple fact that low levels of microwave exposures have biological effects opens the proverbial can of worms, with respect to all the safety studies the microwave industry has NOT done for RF radiation potentially causing OTHER diseases than cancer, while exponentially increasing human exposure to microwaves in a wide variety of new and untested frequencies and devices year after year.
As the BioInitiative Group pointed out:
“The business-as-usual deployment of new wireless technologies is likely to be risky and harder to change if society does not make some educated decisions about limits soon. Research must continue to define what levels of RF related to new wireless technologies are acceptable; but more research should not prevent or delay substantive changes today that might save money, lives and societal disruption tomorrow.” (p 22)34
With respect to involuntary exposure to a potential environmental hazard such as the microwave emissions of smart meters, until compelling scientific research exists establishing their safety—and not just doubt about their ability to harm—one would expect that at minimum governments genuinely concerned about protecting the health and safety of its citizens should at least give them the freedom to choose without penalty whether to opt-out or to opt-in, just as they can for cell phones and other RF emitting devices.
About the Author: Dr. Ed Kellogg earned his Ph.D. in biochemistry from Duke University with research focusing on superoxide reactivity and the role that free radicals play in the aging process. Later at U.C. Berkeley he directed the program at the Air Ion Laboratory, publishing EMF research in the J. Bioelectricity, the International Journal of Biometeorology, and the J. Gerontology. His scientific work has appeared in other peer reviewed journals including Nature, the J. Neurochemistry, the J. Biological Chemistry, Photochemistry and Photobiology, and Toxicology Letters.
1. The Origins of the U.S. Safety Standards for Microwave Radiation. Steneck, N. H. et al, Science, Vol. 208, pp 1230-1237, June 13, 1980. http://www.magdahavas.com/wp-content/uploads/2010/06/steneck_science_1980.pdf
2. Expert Report [on the human health risks of EMF and Smart Meters] of Andrew A. Marino, Ph.D. before the Pennsylvania Utility Commission, August 8, 2016. Dr. Marino has an impeccable and impressive scientific background in this area, with over a hundred publications in peer reviewed journals on the effects of man-made electromagnetic energy on animals and human beings. Exhibit 1 lists his qualifications and research publications. http://andrewamarino.com/PDFs/testimony-AAM_Report.pdf 3. Microwave Exposure Limits — Countries Comparison. http://www.safeinschool.org/p/microwave-exposure-limits-countries.html
4. Radio Frequency Color Charts that summarize many studies that report biological effects and adverse health effects relevant for cell towers, WI-FI, ‘smart’ wireless utility meters, wireless laptops, baby monitors, cell phones, and cordless phones. http://www.bioinitiative.org/rf-color-charts/
5. Cell Phone Radiation Boosts Cancer Rates in Animals: $25 Million NTP Study Finds Brain Tumors. http://microwavenews.com/news-center/ntp-cancer-results
6. NTP cell phone studies — experts recommend elevated conclusions. By Virginia Guidry. https://factor.niehs.nih.gov/2018/4/feature/feature-2-cell-phone/index.htm
7. Report of final results regarding brain and heart tumors in Sprague-Dawley rats exposed from prenatal life until natural death to mobile phone radiofrequency field representative of a 1.8 GHz GSM base station environmental emission. Falcioni, L. et al Environmental Research, Vol. 165, pp 496-503, Aug. 2018. https://www.sciencedirect.com/science/article/pii/S0013935118300367?via%3Dihub
8. Increased blood-brain barrier permeability in mammalian brain 7 days after exposure to the radiation from a GSM-900 mobile phone. Nittby, H. et al, Pathophysiology. Vol. 16(2-3), pp 103-12, Aug. 2009.
9. Effects of Electromagnetic Fields from Wireless Communication upon the Blood-Brain Barrier. [A Review]. Leif G. Salford, MD, PhD., 2012
10. Why children absorb more microwave radiation than adults: The consequences. Morgan, L.L. et al, Journal of Microscopy and Ultrastructure, Vol. 2, Issue 4, pp 197-204, December 2014. https://www.sciencedirect.com/science/article/pii/S2213879X14000583
11. Prevalence of Autism Spectrum Disorder Among Children Aged 8 Years — Autism and Developmental Disabilities Monitoring Network, 11 Sites, United States, 2014. Centers for Disease Control and Prevention.
12. Increases in Depressive Symptoms, Suicide-Related Outcomes, and Suicide Rates Among U.S. Adolescents After 2010 and Links to Increased New Media Screen Time. Twenge, J.M. et al, 1, Clinical Psychological Science Vol. 6, Issue 1, pp 3-17, 2018.
13. Suicide rising across the US: More than a mental health concern. Centers for Disease Control and Prevention. 2018.
14. Statement by Michael Dougherty, Chief Operating Officer, Oregon Public Utility Commission, in a June 6, 2018 mail to Mayor Darby Ayers-Flood of Talent, Oregon. http://www.freedom2sayno2smartmeters.org/wp-content/uploads/2018/08/DoughertyOPUC-toMayor-Darby-060518.pdf
15. WHITEPAPER Radio Frequency Emissions: Analysis of Radio Frequency Exposure Associated with Silver Spring Networks’ Advanced Metering Devices. https://www.silverspringnet.com/wp-content/uploads/SilverSpring-Whitepaper-RadioFrequency.pdf
16. A Primer on FCC Guidelines for the Smart Meter Age, by Amy O’Hair, 2012. https://stopsmartmeters.org/2012/03/09/a-primer-on-the-fcc-guidelines-for-the-smart-meter-age/
17. Use of laptop computers connected to internet through Wi-Fi decreases human sperm motility and increases sperm DNA fragmentation. Avendaño, C. et al, Fertil. Steril. Vol. 97(1), pp 39-42, Jan. 2012. https://www.ncbi.nlm.nih.gov/pubmed/22112647
18. Electromagnetic hypersensitivity: evidence for a novel neurological syndrome. McCarty D.E. et al, Int J Neurosci., Vol. 121(12), pp 670-6, Dec 2011. https://www.national-toxic-encephalopathy-foundation.org/lsustudy.pdf
19. Evaluation of the Aclara I-210+C AMI Meter.” Presented at the City of Talent Oregon Town Hall Meeting by William Bathgate, EE, ME, May 30, 2018. http://www.freedom2sayno2smartmeters.org/wp-content/uploads/2018/06/Evaluation-of-the-Aclara-I-210C-AMI-Meter-v1.3.pdf (For a more detailed report see: http://www.freedom2sayno2smartmeters.org/wp-content/uploads/2018/08/BATHGATE-5-10-18-BB-Evaluation-of-the-Aclara-I-210C-AMI-Meter-v1.22.pdf)
20. Health Impacts of Radio Frequency Smart Meters: April 2011 Final Report, California Council on Science and Technology
21. EPRI (2011) “Radio-‐Frequency Exposure Levels from Smart Meters: A
Case Study of One Model,” Electric Power Research Institute, February 2011.
22. Wireless mesh network. https://en.wikipedia.org/w/index.php?title=Wireless_mesh_network&oldid=852691535
23. Smart Meters: How They Work, Why They Are Harmful. http://www.smartmetereducationnetwork.com/smart-meters-what-they-are-and-what-they-do.php
24. Before the Public Utilities Commission of the State of California, Pacific Gas and Electric company’s response to Administrative Law Judge’s October 18, 2011 Ruling directing it to file clarifying Radio Frequency Information. See Table 2-1. http://docs.cpuc.ca.gov/efile/RESP/149398.pdf
25. Systematic Review of the Exposure Assessment and Epidemiology of High-Frequency Voltage Transients. de Vocht, F. and Olsen, R.G., Front Public Health. Vol 4, 52. 2016. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4810027/
26. As stated by Megan Decker, Chair of the Oregon Public Utility Commission, in a letter to the Jackson County Board of Commissioners in response to their concerns dated July 18, 2018.
27. BioInitiative 2012: A Rationale for Biologically-based Exposure Standards for Low-Intensity Electromagnetic Radiation.
28. Biological Effects from RF Radiation at Low-Intensity Exposure, based on the BioInitiative 2012 Report, and the Implications for Smart Meters and Smart Appliances by R.M. Powell, Ph.D.
29. Before the New Mexico Public Regulation Commission, Case 15-00312-UT, Rebuttal-Testimony of Paul Dart, M.D., dated July 21, 2016.
30. Before the New Mexico Public Regulation Commission, Case 15-00312-UT, Recommended Decision, dated March 19, 2018.
31. How Safe Are Smart Meters? 8/7/2018 version.
32. For example, see: World Health Organization, radiofrequency radiation and health — a hard nut to crack (Review). Hardell, L., Int J Oncol. Vol. 51(2): pp 405–413, Aug. 2017. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5504984/
33. What are electromagnetic fields? Summary of health effects, Conclusions from scientific research. World Health Organization.
34. Key Scientific Evidence and Public Health Policy Recommendations. BioInitiative Group. http://www.bioinitiative.org/report/wp-content/uploads/pdfs/sec24_2007_Key_Scientific_Studies.pdf