What is worth noting is how contrary this report is to the decades of evidence and knowledge that radio frequencies do have actual, non-thermal biological effects. Obviously, with millions in stimulus dollars on the line, any critical examination of this project might jeopardize the funding. What is important, albeit inconvenient to consider is that failing to look this gift horse in the mouth will allow a veritable Trojan Horse into Vermont, with the potential to change the state in irreversible ways.
Let's begin with the indisputable aspects of the report, before examining some of the glaring issues.
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| Painting by Aldro Hibbard |
The [Federal Communications Commission's] maximum permissible exposure limits are established to prevent thermal effects of [radio frequency radiation]. The MPE limit is not based on any non-thermal effects.
A number of reports have appeared in the scientific literature describing the observation of a range of biological effects resulting from exposure to low-levels of RF energy.
[Individual sensitivity to RFR can vary depending on] "flicker" from fluorescent lights, glare and other visual problems with [monitors], poor ergonomic design, poor indoor air quality, and [other sources of] stress.
Populations as a whole are not genetically homogeneous and people can vary in their susceptibility to environmental hazards.
[Electrohypersensitivity] can be a disabling problem for the affected individual.
The use of mobile phones whilst driving is a major issue of concern and experimental evidence demonstrates that it has a detrimental effect on drivers’ responsiveness. Epidemiological evidence indicates that this effect translates into a substantially increased risk of an accident.
It is not possible at present to say that exposure to RF radiation, even at levels below national guidelines, is totally without potential adverse health effects, and that the gaps in knowledge are sufficient to justify a precautionary approach.
The VDH has taken an extremely soft approach to safety by comparing Smart Meter RF emissions to the FCC's 15 year-old MPE limits that only consider how much RF radiation, for a brief period of time, will painfully burn a grown man. This approach assumes that our bodies are TV dinners and that children and women will cook at the same speed under the same power.
Powerwatch.org.uk sums up the main failure of the VDH in one sentence:
The important thing to bear in mind with regard to exposure is not the level compared with the allowed guidelines, but the level compared with what we have been exposed to in human evolutionary terms.
There is no mention of what background RF levels exist in Vermont today, or might have been in the past. Even if this crucial piece of data were included, the unit preferred by the industry and the FCC, microwatts per centimeter squared (µW/cm^2), causes any low level of RF to appear to be practically zero.
Again, from Powerwatch:
The problem occurs because [power density] is ONLY relevant to heating and it averages the power over time (6 minutes for official RF PFD measurements). The best unit of measurement for varying microwave signals at the non-thermal levels we are concerned with is volts per meter.
The VDH says that the only health effect from RF that we need to worry about is heating.
Strike 1.
The VDH says that time averaged radio frequency fields are completely safe if they are at all less than the FCC's MPE.
Strike 2.
The VDH says it is acceptable to use a unit of measurement that makes common RF field exposures indistinguishable from each other.
Strike 3.
Another omission in the report is the "chatter" duty cycle. It would have been simple to confirm or deny GMP's claim that Smart Meters transmit only once every 15 minutes, but this information is left out, leaving the critical reader wondering, "just how often does a Smart Meter pulse?"
The VDH has provided similarly poor advice in the past. About 8 years ago they testified to the Public Service Board regarding VELCO's desire to add high voltage transmission lines, also known as the Northwest Vermont Reliability Project.
Employing questionable logic, they reported:
1. Typical magnetic power frequency fields in the home average 0.6 milligauss and range from 0.1 to 4 mG over a period of a day.
2. New York has established guidelines of 200 mG for right-of-way edges.
3. Florida has established guidelines of 150 mG for right of way edges.
4. Neither the New York and Florida guidelines are based on health effects.
5. The International Commission on Non-Ionizing Radiation Protection (ICNIRP) established guidelines for exposure of the public to magnetic power frequency fields of 833 mG.
Finally:
For the purpose of the Vermont Department of Health’s review of the Vermont Electric Power Company Northwest Vermont Reliability Project, the New York and Florida guidelines were chosen for comparison because they provide the strictest guidelines presently available, even though they are not health-based. When the New York and Florida guidelines were exceeded, the ICNIRP guidelines, which are health-based, were compared with the projected magnetic or electric power frequency fields.
In a later surrebutal testimony:
Q8. Please explain whether VDH has formed an opinion on whether the location of a pole close to the Waldorf School as provided in the Landworks proposed route poses a health risk to the students.
A8. The VDH concludes that the projected magnetic power frequency fields for all alternatives at the closest approach to the school are less than the health-based ICNIRP guideline of 833 mG and therefore would not pose an adverse health risk. The expected EMF from the pole close to the school, as proposed by Landworks, would be expected to increase the EMF from the present levels that currently result from the existing transmission line. The present average EMF level in the Fine Arts room is 1.5 mG and is projected to increase to between 20 mG and 24 mG in 2012 at the wall closest to the railroad track. The EMF strength in the middle of the room will be less due to the increased distance away from the overhead transmission line. The VDH notes that this is 34 times less than the health based ICNIRP standard and is comparable to levels of exposure from computer monitor screens, refrigerator and water coolers used in the school as listed in A7 above. However, this level would not be expected in other areas of the building, due to increased distance from the proposed transmission line and from any metallic material in the walls. The projected EMFs as listed in DPS-VDH-7 are not of concern because these levels are typically encountered in every day life from indoor wiring, appliances, etc.
Clearly, VDH states that 0.6 mG is an average magnetic field found in homes with electricity. Many experts have stated that fields above 3 mG can significantly increase health problems, yet VDH testifies that increasing the field in the Waldorf School's art room from 1.5 mG to more than 20 mG is "not of concern."
The Vermont Department of Health has solidified their stance and refuses to protect Vermonters from high levels of superfluous electromagnetic fields.
For those of you who wish to protect your family's health, I encourage you to take your own measurements, comparing them to what you find away from sources of magnetic fields and RF. As a general rule, try to keep RF fields below 0.2 volts per meter and magnetic fields below 2 mG, especially where you sleep.
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