EMF Safety Network Uncovers Smart Meter FCC Compliance Violations

PG&E has based its radiation (RF) health and safety claims on their assertions that Smart Meters
comply with all Federal Communications Commission (FCC) regulations. The California Public
Utilities Commission (CPUC) has upheld without question or investigation PG&E’s unproven
claims. PG&E must be held accountable for following FCC RF compliance safety rules.

The EMF Safety Network alleges that PG&E Smart Meters violate one or more FCC conditions
that determine RF exposure compliance. The FCC Grants of Equipment Authorization, which
govern the rules upon which FCC compliance is based, warns that RF exposure compliance
depends on specific conditions. The conditions include one or more of the following, depending
on the specific make and model of Smart Meter.

• limited single module approval requires professional installation;
• antenna(s) must provide a separation distance of at least 20 cm from all persons;
• antenna(s) must not be co-located or operating in conjunction with any other
antenna or transmitter;
• end-users and installers must be provided with antenna installation and
transmitter operating conditions for satisfying RF exposure compliance

Network believes that completion of a few weeks of training does not qualify
PG&E’s Smart Meter installers as “professionals.” Based on informal observations,
Network has serious doubts about installer training and professional status. Network suspects
that installers are also not given accurate information about RF operating conditions.

Many Smart Meters are installed within 20 cm of public access. In some cases the meters are
installed inside homes and businesses. In many situations Smart Meters are easily accessible to
the public. This rule is clearly violated.

Smart Meters are widely co-located in banks of multiple meters. Co-location also occurs within
Smart Meters because electric Smart Meters include at least two internal RF antennas. One
antenna is used for the mesh network system and the other is for the Home Area Network (HAN)
systems. Antennas are designed to work in conjunction with the HAN and RF appliances and
with other Smart Meters in a mesh network. Antennas have separate Grants of Equipment
Authorization, which suggests that manufacturers have tested antennas in isolation and
individually, and not in combination, which is how the Smart Meter and the Smart Grid system
were designed to operate.

Network believes “end users,” are the customers. PG&E has not provided end users with
antenna installation and transmitter operating conditions for satisfying RF exposure compliance.
FCC conditions that specify that end users are to have no manual instructions to remove or install
the device confirm Network’s belief that the end user is the customer.

Network alleges one or more FCC exposure compliance violations for the following meters
PG&E is deploying: FCC ID numbers: OWS-NIC514, OWS-NIC507, and LLB6327PWM.

Research into other Smart Meter Grants of Equipment Authorizations indicates there are similar
violations in other utility districts in California. Network is calling for an immediate halt to
the Smart Meter installation in California and a statewide investigation into these FCC
compliance violations. Network further calls for copies of all Grants of Equipment
Authorization for all Smart Meters installed under CPUC jurisdiction, with complete contact
information for laboratory testing personnel responsible for performing RF compliance tests.

Sandi Maurer
EMF Safety Network


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