September 12, 2011 Dear CPUC, Please submit my comments to the public record regarding PG&Es Opt Out

Proposal for the Smart Grid. You will find the comments below as well as in the attached pdf document. Submitted by: Angela Flynn 351 Redwood Heights Road Aptos, CA 95003 831-684-1401 angelaflynn80@msn.com Re: Public Workshop Notice: A.11-03-014 - Application of Pacific Gas and Electric Company for Approval of Modifications to its SmartMeterTM Program and Increased Revenue Requirements to Recover the Costs of the Modification; A.11-03-015 Application of Utility Consumers' Action Network for Modification of Decision 07-04043 so as to Not Force Residential Customers to Use Smart Meters; and A.11-07-020 Application of the County of Santa Barbara, the Consumers Power Alliance, et al For Modification Of D.08-09-039 And A Commission Order Requiring Southern California Edison Company (U338E) To File An Application For Approval Of A Smart Meter OptOut Plan (REVISED AS OF 9/2/11) Comments: In 2006, Gerd Oberfeld, MD projected that 50% of the worlds population will be electrosensitive (EHS, also referred to as radio wave and microwave poisoning) to the microwave radio frequency radiation emitted by our communications transmitters and to the electromagnetic fields of our electrical devices (EMF/RF). Dr. Oberfeld based this projection on sound scientific research, not on supposition. Oberfeld, epidemiologist of the Public Health Department in Salzburg, Austria, along with Orjan Hallberg, of Hallberg Independent Research, Trangsund, Sweden, published the research in the Electromagnetic Biology and Medicine, [25: 189191, 2006 Copyright Informa Healthcare ISSN 1536-8378 print DOI: 10.1080/15368370600873377] Oberfeld was also instrumental with the policy implemented by the city of Salzburg, which has maintained the city as having the lowest electromagnetic radiation levels in Europe. The recommended RF level in Salzburg, Austria is:

Outside (2002) 0.001 W/cm^2 Inside (2002) 0.0001 W/cm^2 The United States FCC RF exposure standard is 1,000 W/cm^2. Why is there such a vast difference in these exposure standards? The FCC standard is based on the irrational belief that EMF/RF only has thermal effects. This belief ignores thousands of studies dating back to the 1950s, which document biological effects at levels thousands of times lower than the FCC standard. Our standard was essentially developed by the military to allow their free use of communications and radar systems. It was not intended for having multiple microwave transmitters in our homes. Russia, Italy, China and Switzerland have exposure standards of 10 W/cm^2. Russia has done extensive research in the field, using human subjects, and found that there is a cumulative effect. That is prolonged exposure leads to pathological responses. If the body is allowed to recover from exposure it can then withstand relatively high exposure for short periods. If it is not given time away from EMF/RF exposure an exposure threshold is crossed and all future exposure will be harmful. A good analogy is our sensitivity to the electromagnetic radiation from sunlight. Some of us are highly sensitive to this EMF/RF and can only withstand very short exposures before harm is done. But all of us are sensitive and prolonged exposure will harm everyone leading to a heightened sensitivity to sunlight until the body is given time to recover. Without this recovery period we could not tolerate any additional exposure. We would not live long if we had unprotected 24/7 exposure to sunlight. While the health effects from the EMF/RF of our electrical devices are not so visible to the naked eye they have been well studied and there are plausible mechanisms for the harm done. *(Please see footnote for two of the mechanisms and common symptoms.) The people who are the most at risk of being pushed into electrosensitivity are those who live near cell towers and/or have microwave transmitters (i.e. WiFi routers, DECT cordless phones, wireless Smart Meters, and other wireless devices) near their sleeping area. This was the case for me. I lived in a home that was 300 feet from cellular antennas on a two-story building. This house was in the main beam of one antenna and at the focus point for the microwaves. After about a year I found I could not sleep for more than 4 hours a night. I woke up exhausted and started to have serious memory problems. I did some research and found that these are typical symptoms of microwave poisoning. I moved from my home and I now keep my EMF/RF exposure as low as possible. I have removed all wireless devices from my home and limit my time at locations that have high levels of EMF/RF. I purchased a RF Detector and shielding material, which aid me in avoiding high exposures. I was able to regain my health, but I must avoid high EMF/RF exposure. If I do not I am pushed back into EHS. I, and others who have been injured by microwave exposure, will not be able to avoid wireless Smart Meters and their wireless mesh grid infrastructure. I am all for the Smart Grid. I realize that our electrical grid needs updating and that constant monitoring of

usage will allow utilities to generate and send energy more on demand with less waste. I think it is debatable if constant monitoring will change the average users consumption. Education will do this. However the toll on public health from the imposition of microwave transmitters on every home and office building will far outweigh any benefit of more efficient energy usage. It is hard to stop a train in motion, but this is what is needed. The majority of the worlds governments, including the United States, need to halt all deployment of wireless Smart Grids and move to wired solutions. It will cost more money to implement and much money has already been misspent, but there is no excuse for allowing this harmful technology to continue. If Chattanooga, TN can implement a fiber optic Smart Grid, than surely California can as well. (See http://www.electricenergyonline.com/?page=show_article&mag=68&article=550) We are the worlds leader in technology and health and it is time that we recognize past mistakes and get back in the lead. The residents in California take the environment and their health seriously and we will not sit back and allow this massive failure to protect our health to continue. While PG&Es Opt Out of wireless Smart Meters is a small step in the right direction, it will not be sufficient. I have been measuring the RF levels at and near PG&Es electric Smart Meters installed in Santa Cruz. I have recorded RF levels as high as 914 W/cm^2 close to a meter and up to 24 W/cm^2 inside a home with a Smart Meter. The level was into the 300s W/cm^2 at 3 feet from a bank of 20 Smart Meters. And, while Itron and PG&E report that the meters will only emit microwaves for a burst of a second every hour, 37 out of the 40 meters I have tested emitted microwaves continuously. The other 3 appeared to be turned off and were on homes that were unoccupied. Something is not adding up here. Perhaps, to give PG&E, some slack, what they meant to say is that information will only be sent to the Smart Grid once an hour. Clearly the radiation is present 24/7. Until fiber is laid for our Smart Grid (and all other broadband communications delivery to homes and businesses), we must continue to use analog meters, which do not pollute our environment with microwaves. It is ludicrous to have a system where the injured people must Opt Out and then pay more in order to regain their health. People are loosing the use of their homes and we, collectively, are loosing countless job productivity hours and even mental abilities to innovate due to the harm done by microwave exposure. Please restore sanity to our wireless policy. For references please refer to the attached report Cell Tower Report: Living with Radio Frequency Radiation. This report may also be accessed at http://www.scribd.com/doc/24352550/Cell-Tower-Rpt Addendum to the report: EHS A Permanent Disability?

On May 23rd, 2011 the Labor Court of Madrid, Spain ruled that EHS is a permanent disability. The ruling is unique in this regard and makes a precedent for future conditions related to hypersensitivity to these waves. The verdict was issued on 23 May and gave the teachers 100% of his base salary, which amounted to 1640.80 euros. http://www.noticiasmedicas.es/medicina/noticias/10451/1/La-hipersensibilidad-a-lasondas-que-producen-los-telefonos-moviles-se-convierte-en-una-nueva-causa-deincapacidad-permanente/Page1.html Safer, and Saner, Wireless Networks A properly functioning mobile network is feasible with much lower radiation levels in homes. The levels could be lowered to such an extent that no-one living in the vicinity of mobile phone masts needs to suffer from neurological effects, such as headaches and migraine. This is (probably) also true for the higher cancer incidence around mobile phone masts, which has been found in several studies. In the present - polarised - public debate regarding the public health effects of phone masts, this fact is largely ignored. We propose here to adopt such a more modern mobile phone network (see safe network), as is already functioning in a number of regions in Europe. The most important message to come from this website is that there is no conflict between having a good functional mobile phone network and the need for a healthy environment. It just needs careful planning and an appreciation of the adverse biological effects of nonionizing electromagnetic radiation. http://www.kennisplatformveiligmobielnetwerk.info/1578592.htm Changes of Clinically Important Neurotransmitters under the Influence of Modulated RF Fields http://www.buildingbiology.ca/input/emf-research-rimbach One of the latest pilot studies from Germany on cell tower radiation and stress hormone levels was discussed in the EMF report by the Standing Committee on the Environment of the European Council, which in May 2011 adopted a resolution on The Potential Dangers of Electromagnetic Fields and Their Effect on the Environment, recommending to take all reasonable measures to reduce exposure to electromagnetic fields. In this study from Bavaria (Germany), urine samples of 60 study participants were taken to be analyzed for their adrenaline, noradrenaline, dopamine, and phenylethylamine (PEA) levels before and after the activation of a new GSM base station. After the activation of the GSM base station, the stress hormone levels increased significantly during the first six months while dopamine and PEA levels decreased substantially. Even after one and a half years, the initial levels were not restored. Sleep problems, headaches, allergies, dizziness, and concentration problems occurred more often. Please note that the cutoff for the highest exposure group was only 100 W/m2, for the lowest exposure group 60 W/m2.

Though the number of participants was small, the findings are very disturbing. PEA levels, for example, continued to decrease over the entire exposure period. Over the past decade not only has the use of wireless devices greatly increased, but the prescription for methylphenidate or Ritalin, whose chemical structure is related to PEA, has as well. The complete study by Dr. Buchner and Dr. Eger is now available in English: Changes of Clinically Important Neurotransmitters under the Influence of Modulated RF Fields http://www.buildingbiology.ca/input/wp-content/uploads/2011/09/RimbachStudy-20112.pdf The original German study is available here: Vernderung klinisch bedeutsamer Neurotransmitter unter dem Einfluss modulierter hochfrequenter Felder (2011) http://www.diagnose-funk.ch/erkenntnisse/nerven-unddruesen/veraenderung-von-neurotransmittern-bei-anwohnern.php Footnotes: The following health effects have been documented in studies of RF radiation: DNA breaks, cancer, endocrine disruption, birth defects, sterility, heart arrhythmia, learning impairment, ADD/ADHD, headache, fatigue and sleep disturbance. People report sleep problems, headaches, ringing in the ears, heart problems, dizziness, nausea, cognitive problems, and other physical ailments from microwave exposure. Biology Explained Two possible mechanisms of non thermal effects from EMF/RF are Oxidative Stress and Calcium Ion Loss. These effects are the result of cellular resonance and occur at levels well below any documented thermal effects. Both of these are likely occurring and easily account for the myriad of symptoms reported by people who have become electrosensitive. Oxidative Stress: A possible mechanism for the development of disease from RF is that the radiation affects the behavior of proteins in cell membranes. When exposed, the membrane produces reactive oxygen species (ROS), which are chemically reactive molecules that occur naturally. However when confronted by stress, ROS molecules shed extra electrons and forms Super Oxide which then combines with Nitric Oxide resulting in the free radical Peroxynitrite (NO3) which has a negative charge. (See http://www.citizensforsafetechnology.org/World-expert-explains-link-between-EMFand-human-disease-radiation-in-Ireland-1000-times-higher-than-recommendation,6,883) http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3062017/ Indian J Occup Environ Med. 2010 Sep-Dec; 14(3): 6670. doi: 10.4103/0019-5278.75692

Oxidative stress, melatonin level, and sleep insufficiency among electronic equipment repairers Mohamed El-Helaly and E. AbuHashem1http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3062017/ It has been shown in numerous studies that ROS are directly involved in oxidative damage of cellular macromolecules, such as lipids, proteins, and nucleic acids in the tissues. Free radicals are very reactive and unstable molecular fragments that have an unpaired electron and they can produce new free radicals by means of chain reactions. These molecules, although formed as a result of normal biochemical processes, sometimes may be damaging and interact with all the macromolecules, including lipids, nucleic acids, and proteins. Particularly susceptible to oxidative damage by free radicals are the polyunsaturated fatty acid acyl chains of phospholipids, which lead to lipid peroxidation. Uncontrolled lipid peroxidation is a toxic process resulting in the deterioration of biological membranes. the consequences of sleep deprivation and sleepiness have been noted as a tremendous burden on our modern society and life, including an increase in mortality and morbidity, errors and accidents, absenteeism, a decrease in productivity, and the deterioration of personal and professional relationships. Calcium Ion Loss: According to Andrew Goldsworthy, BSc, PhD, our wireless communication devices use amplitude-modulated radio waves where the signal strength rises and falls. These have been shown to be further damaging as they can remove structurally important calcium ions from cell membranes at levels far below the thermal effect. This results in an increased leakage of materials through cell membranes that can affect many aspects of metabolism. These include damage to DNA, from digestive enzymes leaking from lysosomes, apoptosis (cell death), the generation of false nerve impulses from calcium leakage in brain cells (causing hyperactivity, impairing normal mental function and generating many of the known symptoms of electromagnetic hypersensitivity.) Claims by the industry that the cellular antennas are safe because the radiation falls off rapidly with distance are flawed. The biological response will remain more or less constant over a wide range of signal strengths due to the ways in which living cells routinely use negative feedback to compensate for changes in their environment. (See http://bemri.org/archive/hese-uk/en/niemr/scientists.php)