Sunday, February 16, 2020

Will the WSSC Ensure Our Safety? Read a Letter to the WSSC

Letter to the WSSC by Montgomery County Citizen
This was sent yesterday.. 

WSSC Commissioners –

It was very disappointed to receive the February 14, 2020 email from the AMI Project about the February 19th meeting and attached health study (“Report”) conducted by WSSC. It was also very disappointing to receive a note from the AMI Project about how the study was conducted. This e-mail preceding the February 19th seems to say that since a public agency has not found RF harmful to human health, you will take no action. The WHO has classified RF as a Class 2B Human Carcinogen and there have been discussions of increasing this to a Class 1 at the urging of scientists over the past few years.  Calls to the American Cancer Society indicate that they may be revisiting their review of RF and I am not sure they would weigh in on other health effects than cancer. 

I do not understand why the limit on public agency and why the conclusion of no harm to human health given the WHO classification and the NTP study. 

Additionally, the following organizations have studied RF safety:
•             World Health Organization;
•             American Cancer Society;
•             National Toxicology Project (National Institutes of Health); and
•             International Agency for Research on Cancer.

Because of these studies, no public agency has identified RF as harmful to human health.


  1. As far as the Report, it notes that smart meters should clearly fall below the FCC guidance for RF.  However, the FCC standard for measuring the health effects of electromagnetic radiation is based on whether the exposure, on average, will heat human tissue over short periods (six minutes for occupational work and 30 minutes for public exposure). That standard was adopted in 1996 and was based on data from the 1980s to so hear that smart meters will fall below this is no comfort. The standard also does not assume 24/7 exposure. 

  1. Page 17 of the Report states that “About 60% of WSSC water meters are located inside the basements of homes. Whereas, 40% are located outside the home at the property line…The distance from the front door to the property line can vary much with minimum distances of about 5-10 feet… Therefore, in general, meters are located away from the area where people spend time.”

My water meter is located directly on my home – on the wall opposite a basement office where my children study.  This means it would be within 5 feet of them. My home is not unusual in my community of 85 homes in Potomac MD. I am unaware of any home in my community where a meter is at the property line and not affixed directly to the home. 

  1. Further, p. 18 of the Report states that “No exposure assessment studies focused on water smart meters have been identified, however several studies have looked at electric smart meters. Given that exposure from electric meters is likely to be higher than that of water meters they are reviewed below as representative of an upper bound.”  

If there is no study then how can the conclusion be made that these are “better” than a PEPCO smart meter (which allows for OPT OUT to its customers) and that they are safe?

  1. In regard to the studies cited in the Report, why are so many based a small sampling of residences located outside the U.S. and not subject to U.S. standards? Studies like the bioiniative report are not included in your Report. 

Why? Please refer to the case filed by Montgomery County, Maryland that cites to a variety of health reports on RF. Why were those reports NOT considered by you? See June 10, 2019 filing – page 11 and page 55 discuss current research on RF health effects and the non-thermal health effects raised by RF.  https://www.khlaw.com/Files/39783_Montgomery_County_Brief.pdg.

  1. Was the researcher who prepared your Report an independent third party? Many concerned citizens raised this issue with you prior to the undertaking of this report and I assume, like myself, did not receive a response on who was to conduct the Report and what materials would be considered and if the WSSC commissioners would be open to hearing from scientists. General research indicates that he author may not be an independent third party and this is very concerning. Did you invite any members of the scientific community to speak with you or was it solely this one author and this short Report?

See link below regarding Dr. Kheifets.


The Report references the Itron meter. Attached below is an excerpt from Itron’s most recent shareholder report filed on Form 10-K with the SEC.  It notes that “we may face adverse publicity, consumer or political opposition, or liability associated with our products.” 

The safety and security of the power grid and natural gas and water supply systems, the accuracy and protection of the data collected by meters and transmitted via the smart grid, concerns about the safety and perceived health risks of using radio frequency communications, and privacy concerns of monitoring home appliance energy usage have been the focus of recent adverse publicity. Unfavorable publicity and consumer opposition may cause utilities or their regulators to delay or modify planned smart grid initiatives. Smart grid projects may be, or may be perceived as, unsuccessful….. We may be subject to claims that there are adverse health effects from the radio frequencies utilized in connection with our products. If these claims prevail, our customers could suspend implementation or purchase substitute products, which could cause a loss of sales.



I hope the WSSC Commissioners will consider the following prior to implementing any smart meter roll-out?

  1. Did WSSC ask for any current pending or settled actions or claims from companies such as Itron on health, privacy or similar issues as they have disclosed above?

  1. Did WSSC consider that not every customer’s meter falls within the 60/40 categorization noted in the Report. 

  1. Will WSSC provide for an opt-out like PEPCO does (with a fee or no fee)?

  1. Will WSSC guarantee the number of times per day the meter will transmit?  There are reports that transmissions vary widely from a few times a day to a few times a minute.  How will WSSC guarantee this?  How many times will WSSC test its meter to ensure they are only transmitting infrequently as the Report states?  Will it have drivers that will come to our homes and measure this and provide us this information on our quarterly WSSC bills? If so, how frequently?

  1. Will WSSC consider customer re-location of water meters that back to a bedroom or another room that is frequently used? The Report assumes that the meters are “conveniently located” in unused portions of one’s home.

  1. Will WSSC guarantee the safety RF level of the meters or seek a guarantee from Itron or the meter provider it uses? Will this guarantee be made publicly available? Will WSSC require the meter provider to (or will WSSC employees) test the RF levels of the meter and on what type of periodic basis will this be done?  Will the test results be made public?

 I hope the Commissioners will take seriously their review of this report and complete their due diligence on this topic and, at an absolute minimum, provide an opt out for those who do not wish to have these meters attached to their homes. 

Thank you,
XXXX Citizen of Montgomery County  MD 

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