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1 From: Sent: Monday, October 30, :24 PM To: Jenna Lesch Subject: Comments for the November 1 Committee meeting...caution EXTERNAL SENDER: Do not open links/attachments if uncertain about the sender... October 30, 2017 Ms. Lesch, Here are my comments on these two meetings. SMUD will act on these proposed "FEES AND TERMS AND CONDITIONS OF USE FOR SMUD UTILITY POLES" according to its "special notice", at these meetings. ENERGY RESOURCES & CUSTOMER SERVICES COMMITTEE AND SPECIAL BOARD OF DIRECTORS MEETING 5:30 p.m., November 1, 2017 and BOARD OF DIRECTORS MEETING 6:00 P.m., November 16, pdf Will you forward my comments to Mr. Orchard, Ms. Lewis, each Director and any staff member who has substantial input into the contents of the fees and terms and conditions for use of SMUD's utility poles by communications service providers? Also, I have embedded sixteen (16) photographs in the body of this . Will you let me know if those have come through and you can see them? Thank you. Mr. Orchard, Ms. Lewis, Directors and staff, I will not be able to attend the November 1 meeting. I may attend the November 16 meeting. Please consider these comments and recommendations for changes in the fees and terms and conditions for use of SMUD's utility poles by communications service providers. SMUD is breaking new ground here. It is very important that SMUD make these terms and conditions right. Doing them right the first time will prevent problems and will be much easier than revising these terms and conditions later after problems have occurred. It may be too late. If SMUD allows the communications service providers (CSPs) to do certain things because of omissions in these terms and conditions, SMUD may not be able to revise them so as to undo the problem later. SMUD doesn't want to open the door to foreseeable and avoidable problems. SMUD has been very thorough and careful in many areas with these terms and conditions. However SMUD has omitted a couple of areas where it ought to set terms and conditions. #1) Page 1 of the document called "FEE AND TERMS AND CONDITIONS OF USE FOR SMUD UTILITY POLES", September 11, 2017 says, "State law requires SMUD to make space and capacity on utility poles and support structures available for use by CSPs pursuant to 'reasonable terms and conditions.'" What section(s) of what Codes is this referring to? #2) Earlier this year SAIC Wireless on behalf of Verizon Wireless filed application MT-09, for permission to install a cell antenna and related equipment on a SMUD utility pole near 2330 Q Street in Sacramento. At the same time it also filed about 15 very similar applications in the same area of Sacramento.

2 From the pictures in the application the pole appears to be 20 to 25' from a residence (a single family house). Since SMUD is the property owner (owns the utility pole) it appears that this equipment could only be installed if SMUD approves the application. SMUD must make a decision on each of these applications and on many more that have not even been filed. This is not SMUD's opportunity to pass the buck. #3) Exhibit 2, page 8 of the proposed terms and conditions says: Radio Frequency Emissions CSP equipment shall at all times comply with Federal, state and local standards and other Laws pertaining to radio frequency emissions. CSP equipment shall not at any time exceed the radio frequency energy emission limits established by Law. Please notice that nothing in the terms and conditions requires the CSP to monitor the radio frequency emissions from their cell antennas. Nothing. Therefore this requirement cannot be met. Absent monitoring neither the public nor SMUD nor the CSP will have any way of knowing whether the CSP's equipment on a given SMUD utility pole complies with Federal, state and local standards etc. pertaining to RF emissions. There must be a provision for RF emission monitoring. I recommend adding the following text to the section on RF emissions: "The CSP at its own expense will devise a monitoring plan to ensure the CSP equipment's compliance with the 'standards and other laws' described here. Such monitoring plan will be subject to SMUD's approval and shall be in place, approved by SMUD (with any revisions required by SMUD) prior to the installation of the equipment. The CSP or its agent shall monthly conduct testing and the CSP s expense to monitor the emissions of its equipment and shall report the full results of its testing to SMUD." "In addition, at the CSP's expense SMUD will conduct random monitoring of the cell antenna (or "small cell") and related equipment at least four times per year. The time and date of the monitoring will be randomly selected by SMUD and not known to the CSP. If the equipment is found to exceed the radio frequency emission limits established by law the CSP will immediately repair or remove and replace the equipment with equipment that it demonstrates, on the day or repair or replacement, complies with said limits, and shall also pay to SMUD a fine in the amount of $5,000." #4) Nothing in the proposed terms and conditions will limit the amount of noise that these cell antennas placed on SMUD utility poles will produce. This is essential. You do not want to give the CSPs carte blanche to put up a noisy machine, especially because with the 16 or so applications that SAIC Wireless on behalf of Verizon Wireless filed earlier this year these utility poles are about 20 to 25 feet from single family homes. Unless SMUD places some limits on the amount of noise the CSPs are likely to put noisy or very noisy machines up. This has already happened in other communities. Imagine if it happened to you, Mr. Orchard and Ms. Lewis and Directors. Imagine if Verizon were to put up a cell antenna on a SMUD utility pole 20 to 25' from your house, let's say from your bedroom window. And that cell antenna made a lot of noise 24 hours a day, not because it was broken or malfunctioning but just because it was designed to be noisy. The fan is the part most likely to be noisy but there could be other parts. Your sleep would be disturbed by this equipment. There would be nothing you could do about it. That would be a very poor policy outcome from a very poor policy. #5) Regarding the permit MT-09 that SAIC Wireless on behalf of Verizon Wireless filed application, for permission to install a cell antenna and related equipment on a SMUD utility pole near 2330 Q Street in Sacramento and in particular the RF caution signage (sic), which looks like this

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4 The "RF caution signage" (page 27) says, "Beyond this point: Radio frequency fields at this site may exceed FCC rules for human exposure." As SMUD evaluates this application how will it define "this point" and "Beyond this point"? The utility pole is accessible from 360 degrees around (pages 31 and 32). There is no fence or other barrier between the public property and this pole. The pole is within the public right of way. It is unclear where "this point" or "beyond this point" are. But this is key information according to the safety warning on the sign. It appears that "this point" should identify a circle of a given radius; however the applicant has not identified any such circle or radius. Will SMUD require the applicant to identify "this point"? Please note I am NOT asking about the FCC rules for human exposure to RF radiation. Only about SMUD's handling of this application, which make reference to those rules but is very ambiguous about how SMUD or the applicant will handle this and what area the warning sign is talking about. My recommendation is for SMUD to define the area within which, according to the applicant or SMUD, Radio frequency fields may exceed FCC rules for human exposure, and SMUD shall require the applicant to create and maintain a physical barrier preventing access within that area from any point 360 degrees around. #6) SMUD should learn from the mistakes that Palo Alto, California made when allowing cell antennas in a residential area, causing extreme health hazards due to radio frequency / microwave radiation. Crown Castle applied for permission to install its cell antennas in downtown Palo Alto. The City approved the applications and Crown Castle installed the antennas and began operating them in November, Unfortunately because of the power of these antennas and their proximity to homes and public places these created extreme health hazards. As a responsible member of the community SMUD wants to avoid this. Credit: All RF/MW radiation and EMF precision instruments and metering services provided by Eric Windheim, Certified BBEC, EMRS, and owner of Windheim EMF Solutions. The Gigahertz Solutions HF-59B documentation specifies how to properly meter and report the high crest factor signals with needle-like, microsecond bursts of power used in the 4G/LTE signals (with OFDM/OFDMA modulation) that are emitted by these Small Cell antennas in downtown Palo Alto. DOSE or total exposure over time, is the relevant concept to any physician evaluating exposure to a toxic agent or to any toxicology study, including the $25-million, 16-year 2016 National Toxicology Program Study on Carcinognenesis of RF/MW radiation. Dr. Ronald L. Melnick, the lead designer of the NTP study stated on 6/1/16: Risk is determined from both the dosimetry, which is the absorbed power [multiplied by] time [of exposure], versus the tumor response... because of the large number of [exposed human] users worldwide, even a small increase in risk at exposure propensities that may be close to what humans experience, could result in a large number of people developing a RF-radiation-induced tumor with long-term exposure. When they wrote the 1996 Telecommunications Act, the Wireless industry lobbyists conveniently left out of the FCC RF/MW radiation exposure guidelines any concept of total exposure over time. These lobbyists and FCC regulators wrote into law fraudulent, scientifically-unsound, RF/MW exposure guidelines based on a rate of exposure, not based on the total exposure over time: this obvious trick is considered utter nonsense by competent physicians or PhD biologists, working in the field. The Wireless industry lobbyists based their RF/MW radiation exposure guideline on a false and scientifically-unsound assumption that living organisms can dissipate the biological effects of RF/MW radiation exposures. Substantial scientific evidence (over 25,000 studies since the 1920 s) have proven immediate and direct short-term biological damages from RF/MW radiation exposures at levels far below what we measured on Palo Alto sidewalks on 4/21/17. There are also long-term biological damages caused by these levels of RF/MW radiation. Immediate direct hazards from RF/MW radiation exposures: adverse effects on blood, brain, heart, hormone, sleep and neurological functions, including tinnitus, insomnia, difficulty concentrating, heart palpitations and suppression of melatonin. Melatonin is a critically-important hormone needed to fight cancer and maintain circadian rhythms. All of this has been established

5 in tens of thousands of peer-reviewed scientific studies and these adverse bio-effects are seen at RF/MW radiation levels far below the scientifically discredited FCC RF/MW radiation guidelines. (BioInitiative 2012,PowerWatch Study List, EMF Scientists Appeal) Long-term hazards from RF/MW radiation exposures: early dementia and deadly cancers of the brain, heart, breast, colon and testicles. (IARC Monograph 102, Lennart Hardell s Additional Work after 2011, 2016 NTP Study on Carcinogenesis of RF/MW radiation exposures. DOSE is explained by these excellent Dr. Karl Maret videos: and DOSE is also shown and explained here. Here are the relevant biologically-based RF Microwave Exposure guidelines: No Hazard Slight Hazard Severe Hazard Extreme Hazard less than 0.1 µw/m² 0.1 µw/m² to 10 µw/m² 10 µw/m² to 1000 µw/m² greater than 1000 µw/m² Measuring peak, not average, levels of RF/MW radiation is critical to fully understand the hazards created by the RF/MW radiation levels that are now present on the downtown Palo Alto sidewalks. RF/MW radiation of 720,000 µw/m² to 1,230,000 µw/m² is EXTREMELY HAZARDOUS. Note: µw/m² means microwatt (or 1/1,00,000th of a Watt) per square meter: Peak RF/MW radiation levels higher than 10 µw/m² is a severe hazard. Peak RF/MW radiation levels higher than 1,000 µw/m² is an extreme hazard. Following are some photographs showing this. The above is a faux mailbox power supply by Crown Castle in downtown Palo Alto.

6 This Small Cell antenna is 12 feet from a 3rd-story balcony, which is a severe health hazard.

7 Site P05m: Florence Street/University Avenue There are no warning signs on either the faux-mailbox power supply cabinet or the pole housing the Small Cell antenna about the RF/WM radiation or magnetic field hazards.

8 Site P04m: Ramona Street/University Avenue Power supplies on narrow sidewalks, like this, impede pedestrian traffic in public right of way.

9 A cell phone tower 15 feet from 2nd-story bedroom windows is not desirable.

10 The faux-mailbox also exposes people to magnetic fields of 5 milligauss or higher; because the mailbox lacks warning signs, anyone could lean up against this cabinet in the public right of way.

11 The screen of the HF-59B meter shows a peak RF/MW radiation reading of 72,000 µw/m², while standing on the sidewalk beneath the Small Cell. Applying the correction factor for high-speed pulsed digital signals (explained here), the peak levels of 4G/LTE RF/MW radiation are actually over 720,000 µw/m². This is an extreme health hazard.

12 Site P04m: Ramona Street/University Avenue The screen of the HF-59B meter shows a peak RF/MW radiation reading of 88,000 µw/m², while standing on the sidewalk beneath the Small Cell. Applying the correction factor for high-speed pulsed digital signals (explained here), the peak levels of 4G/LTE RF/MW radiation are actually over 880,000 µw/m². This is an extreme health hazard.

13 Site P05m: Florence Street/University Avenue The screen of the HF-59B meter shows a peak RF/MW radiation reading of 96,000 µw/m², while standing on the sidewalk beneath the Small Cell. Applying the correction factor for high-speed pulsed digital signals (explained here), the peak levels of 4G/LTE RF/MW radiation are actually over 960,000 µw/m². This is an extreme health hazard.

14 Site P19m: Hamilton/Emerson Streets at Yoga Source The screen of the HF-59B meter shows a peak RF/MW radiation reading of 100,000 µw/m², while standing on the sidewalk beneath the Small Cell. Applying the correction factor for high-speed pulsed digital signals (explained here), the peak levels of 4G/LTE RF/MW radiation are actually over 1,000,000 µw/m². This is an extreme health hazard.

15 Site P15m: Lytton Ave./Bryant Street, Across from Cogswell Plaza This Small Cell antenna is 12 feet from a 2nd-story balcony, which is a severe health hazard. The screen of the HF-59B meter shows a peak RF/MW radiation reading of 18,190 µw/m², while standing on the sidewalk across the street about 100 feet from the Small Cell. Applying the

16 correction factor for high-speed pulsed digital signals (explained here), the peak levels of 4G/LTE RF/MW radiation are actually over 181,900 µw/m². This is an extreme health hazard. The screen of the HF-59B meter shows a peak RF/MW radiation reading of 114,000 µw/m², while standing on the sidewalk beneath the Small Cell. Applying the correction factor for high-speed pulsed digital signals (explained here), the peak levels of 4G/LTE RF/MW radiation are actually over 1,140,000 µw/m². This is an extreme health hazard.

17 Site P01m: High Street/University Avenue Small Cell antenna directed at 2nd story windows nearby.

18 The screen of the HF-59B meter shows a peak RF/MW radiation reading of 123,000 µw/m², while standing on the sidewalk beneath the Small Cell. Applying the correction factor for high-speed pulsed digital signals (explained here), the peak levels of 4G/LTE RF/MW radiation are actually over 1,230,000 µw/m². This is an extreme health hazard. #7) On March 10, 2017 I wrote to SMUD's Randal Edwards, whom I found while trying to find SMUD's Kimberly Bates, whose name appears on page 20 of application MT-09, with some questions about how SMUD will handle these applications. Among my questions were: 6. Does SMUD have, or will SMUD require as part of its review, information demonstrating that this equipment is safe to operate as designed this close to a home? (24/7 unmanned operation according to the application (page 15) 7. The "RF caution signage" (page 27) says, "Beyond this point: Radio frequency fields at this site may exceed FCC rules for human exposure." As SMUD evaluates this application how will it define "this point" and "Beyond this point"? The utility pole is accessible from 360 degrees around (pages 31 and 32). There is no fence or other barrier between the public property and this pole. The pole is within the public right of way. Therefore it is unclear where "this point" or "beyond this point" are but it is clear from the caution signage that there may be radio frequency radiation that exceeds the FCC rules depending on how close to the equipment one gets. It appears that "this point" should identify a circle of a given radius; however the applicant has not identified any such circle or radius. Will SMUD require the applicant to identify "this point"? Please note I am NOT asking about the FCC rules for human exposure to RF radiation. Only about SMUD's handling of this application.

19 8. SMUD Board policy SD-6, Safety, says in part: Public Safety a) Track and report injuries to the public related to SMUD operations or facilities. b) Implement measures to protect the public from injuries related to SMUD operations or facilities. What steps will SMUD take to protect the public from injuries related to the RF radiation from the equipment? As described above in 7 the simple placement of the RF caution signage does not appear to be adequate. That led to a delay of 5 1/2 weeks by SMUD (Jenna Lesch) in responding to my questions. Mr. Edwards never did. Ms. Lesch avoided answer all questions related to the electromagnetic fields (EMFs) that the applicant's equipment on SMUD's utility poles will create. These were questions about SMUD's decisions and SMUD's Board policy SD-6, Safety, which nobody else but SMUD can answer. Ms. Lesch wrote to me on April 17 and said, "Questions regarding radio frequency should be addressed to the project applicant." Dodging the issues. Only SMUD can answer question 6, which was clearly about SMUD's review of information leading to its approval or denial of the application. SMUD is the appropriate party to answer question 7 because this application (and all of them) are for permission to place EMF emitting equipment on SMUD utility poles. SMUD can approve or deny these applications and the "RF caution signage" in the application at page 27 is inadequate. Because SMUD, and not the applicant, has SMUD Board Policy SD-6, Safety, that was an irrelevant answer. Only SMUD can answer question 8. Please provide answers to these questions prior to the November 16 Board meeting. It's not just the members of the public who need answers. The Directors and staff need to have SMUD's answers to these questions too. Thank you. Mark Graham Sent from my hard wired, non-emf emitting computer