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

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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

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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

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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

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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 (HFVT)—popularly known as
“dirty electricity” (DE).19 Although in a few epidemiological studies people
have reported harmful effects from exposures to HFVT, 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

6
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

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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.

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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.

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Bottom Line

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.

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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.

REFERENCES

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N. H. et al, Science, Vol. 208, pp 1230-1237, June 13, 1980.
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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
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6. NTP cell phone studies — experts recommend elevated conclusions. By

Virginia Guidry. https://factor.niehs.nih.gov/2018/4/feature/feature-2-cell-
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7. Report of final results regarding brain and heart tumors in Sprague-Dawley

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10. Why children absorb more microwave radiation than adults: The
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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

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the-smart-meter-age/

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17. Use of laptop computers connected to internet through Wi-Fi decreases
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http://www.freedom2sayno2smartmeters.org/wp-
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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.

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http://www.freedom2sayno2smartmeters.org/wp-
content/uploads/2018/08/OPUC-Response-to-JCBC.pdf

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http://www.bioinitiative.org/

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.
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appliances_june_11_2013.pdf

29. Before the New Mexico Public Regulation Commission, Case 15-00312-UT,
Rebuttal-Testimony of Paul Dart, M.D., dated July 21, 2016.
http://www.freedom2sayno2smartmeters.org/wp-
content/uploads/2018/05/Rebuttal-Testimony-of-Paul-Dart-M.D.-1.pdf

30. Before the New Mexico Public Regulation Commission, Case 15-00312-UT,
Recommended Decision, dated March 19, 2018.
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18-15-00312-ut-recommended-decision.pdf

31. How Safe Are Smart Meters? 8/7/2018 version.

https://www.pacificpower.net/ya/smart-meters/safe-and-secure.html

32. For example, see: World Health Organization, radiofrequency radiation and
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405–413, Aug. 2017.
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5504984/

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from scientific research. World Health Organization.
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34. Key Scientific Evidence and Public Health Policy Recommendations.

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content/uploads/pdfs/sec24_2007_Key_Scientific_Studies.pdf

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