Report of Results of Smart Meter RF Testing - Maui Prepared by CASCADIA PM, LLC. And Presented to HAWAII NATURAL ENERGY INSTITUTE

Transcription

1 Report of Results of Smart Meter RF Testing - Maui Prepared by CASCADIA PM, LLC And Presented to HAWAII NATURAL ENERGY INSTITUTE April 15, 2014

2 Executive Summary 15 April 2014 RE: Report of EMR assessment of Smart Grid Meters and Access Point performed on 20 Feb This report reflects the pre and post antennae activation electromagnetic radiation assessment operating Smart Meters at 5 locations: Meter Mapu Place Kihei, Maui ', ' Meter Kupulau Drive Kihei, Maui ', ' Meter Keha Drive Kihei, Maui ', ' Meter Pawali Street Kihei, Maui ', ' Meter Kupulau Drive Kihei, Maui ', ' and one Access Point (AP) location: AP 1 near 1060 Kupulau Drive Kihei, Maui ', ' The results contained in this report are summarized below. For a detailed technical discussion of our findings the reader is referred to the complete report attached to this summary. Table 1 below tabulates the pre-activation average and maximum readings in milliwatts per square centimeter (mw/cm 2 ) in column A, the the post-activation average and maximum readings in milliwatts per square centimeter (mw/cm 2 ) in column B, and the average and maximum readings of the postactivation readings in percentage of the IEEE Standard obtained in each area assessed in column C. Columns D and E present the acceptable FCC standard guideline for the general population and occupational standard in the State of Hawaii. General population or uncontrolled exposures apply in situations in which the general public may be exposed, or in which persons that are exposed as a consequence of their employment may not be fully aware of the potential for exposure or cannot exercise control over their exposure. Occupants of the homes where the meters are installed fall into this category of general population. Column C lists the occupational exposure percent of standard maximum for the five smart meter locations surveyed. The readings near the meters did not exceed 0.015% of the maximum permissible exposure (MPE) limit of 0.6 mw/cm 2. Occupational or controlled limits apply in situations in which persons are exposed as a consequence of their employment. These persons should be fully aware of the potential for exposure and can exercise control over their exposure. Limits for occupational exposure also apply in situations when an individual is transient through a location where occupational/controlled limits apply provided he or she is made aware of the potential for exposure. Column C lists the occupational exposure percent of standard maximum for the access point location surveyed. The readings did not exceed % of the higher 10 mw/cm 2 standard near the access point located atop a utility pole. Report - Smart Meter RF Testing prepared by Cascadia PM April 2014 Page 2

3 Table 1. Summary of Survey Results Site No. / ( A ) ( B ) ( C ) Test Location No. / Pre activation Post activation Post activation HF 35C orientation Power Density Power Density (H or V) (µw/m 2 ) (µw/m 2 ) (% of standard D) Meter 1/1 H % Meter 1/1 V % Meter 1/2 H % Meter 1/2 V % Meter 1/3 H % Meter 1/3 V % Meter 1/4 H % Meter 1/4 V % Meter 2/1 H % Meter 2/1 V % Meter 2/2 H % Meter 2/2 V % Meter 2/3 H % Meter 2/3 V % Meter 2/4 H % Meter 2/4 V % Meter 3/1 H % Meter 3/1 V % Meter 3/2 H % Meter 3/2 V % Meter 3/3 H % Meter 3/3 V % Meter 3/4 H % Meter 3/4 V % Meter 4/1 H % Meter 4/1 V % Meter 4/2 H % Meter 4/2 V % Meter 4/3 H % Meter 4/3 V % Meter 4/4 H % Meter 4/4 V % Meter 5/1 H % Meter 5/1 V % Meter 5/2 H % Meter 5/2 V % Meter 5/3 H % Meter 5/3 V % Meter 5/4 H % Meter 5/4 V % ( D ) ( E ) FCC State of HI General population / Occupational / uncontrolled standard controlled standard ( µw/m 2 ) (100,000,000 µw/m 2 ) Report - Smart Meter RF Testing prepared by Cascadia PM April 2014 Page 3

4 Site No. / ( A ) ( B ) ( C ) Test Location No. / Pre activation Post activation Post activation HF 35C orientation Power Density Power Density (H or V) (µw/m 2 ) (µw/m 2 ) (% of standard D) Access Point 6/1 H always on not tested NA Access Point 6/1 V always on not tested NA Access Point 6/2 H always on % Access Point 6/2 V always on % Access Point 6/3 H always on % Access Point 6/3 V always on % Access Point 6/4 H always on % Access Point 6/4 V always on % ( D ) ( E ) FCC State of HI General population / Occupational / uncontrolled standard controlled standard ( µw/m 2 ) (100,000,000 µw/m 2 ) 100,000, ,000, ,000, ,000, ,000, ,000, ,000, ,000,000 Measured signal levels in this survey do not create a hazard to the public. The measured levels are well within United States FCC guidelines for the limitation of human exposure to radio frequency (RF) energy. Review of the data tabulated above indicates that the average power density readings at the five smart meter sites do not exceed 0.015% of the maximum exposure level standard for the general population and the readings taken at the access point site do not exceed % of the maximum level for occupational controlled conditions. Report - Smart Meter RF Testing prepared by Cascadia PM April 2014 Page 4

5 21 March 2014 Mr. Christian Rawson Hawaii Natural Energy Institute School of Ocean & Earth Science Technology University of Hawaii at Manoa 1680 East-West Road, POST 109 Honolulu, HI Report of EMF assessment of Smart Grid Meter and AP performed on 20 February 2014 Dear Mr. Rawson: The results of electromagnetic radiation (EMR) survey that was conducted by the undersigned investigator at the five smart meter sites at residences and one access point (AP) site installed on a utility pole located in Kihei, Maui is documented herein. The survey was conducted to assure that residents of the five smart metered homes, MECo personnel working on the utility pole links, and other individuals who can be near the smart meters, are not potentially overexposed to electromagnetic radiation generated and transmitted by the smart meter or access point transmitter. This survey was conducted on the morning on 19 February 2014 between 8:30AM and 5:30 PM on a normal weekday. Radio frequency (RF) field measurements were taken at multiple locations on the grounds around the Smart Meter and from a bucket truck around the pole mounted Access Point. The weather was sunny and degrees on the day of our inspection. The GE I-210 Smart Meter is the subject of the tests conducted. Specifically, the radio transmitter, manufactured by Silver Sprint Networks, is the device under test. The radio is similar to a cell phone transmitting at 1 Watt effective radiated power (ERP), but in the Industrial-Scientific-Medical (ISM) frequency band from MHz. The radio transmitter in the meter transmits data intermittently to the nearest access point device, which relays the data to the MECo data collection station via existing private telecommunication infrastructure. Electromagnetic radiation (EMR) measurements from the smart meter and access point devices were recorded utilizing a Gigahertz Solutions HF-35C 800 MHz to 2.5 GHz RF Analyzer. The Gigahertz Solutions HF-35C RF Analyzer is fitted with a Log-Periodic antenna array, which when pointed in the direction of the transmitter, will measure the strength of the radiation field density around the smart meter. The test instrument has a signal measurement range from 1 uw/m 2 to 2000 uw/m 2 to capture the expected signal levels. The instrument readings in microwatts per square meters can be converted to milliwatts per square centimeters in the range of mw/cm 2 to mw/cm 2. The Gigahertz Solutions HF-35C test instrument was purchased in 2014 and the manufacturer calibrated the instrument. The accuracy of these standards is traceable to the National Institute of Standards and Technology (NIST) to the extent allowed by accredited NIST s calibration facilities. Measurements are generally obtained at arm s length in direction of the emitters. The probe was held at the maximum distance from the tester s body and away from potential reflective objects. The RF measurements were logged for each axis (horizontal and vertical) in order to obtain a temporal and spatial average power density value. Report - Smart Meter RF Testing prepared by Cascadia PM April 2014 Page 5

6 Measurement results The measurements of the actual RF emissions from the five individual smart meters were recorded from various locations around the smart meters. The measurement of the energy emissions covered the radio frequency range of MHz microwave band signals generated by the smart meter device. The smart meter transmits at in the 900MHz frequency band. The RF emission measurements were made in front of the smart meter antenna, 5 feet away, 20 feet away and 50 feet away from the meter. The tests made immediately in front of the meter (position 1 in Figure 1 below) were found to be inconsistent due to the physics of wave generation the meter specification requires a minimum of 5 feet from the transmitter to measure reliably. Figure 1: Depiction of top and side views of the test locations near the meter. The test readings were taken twice at each test location for each meter site, once in the horizontal plane and once in the vertical plane while the smart meter device was off (pre activation); and twice with the smart meter on (post activation). The variance in the pre and post activation readings shall represent the measured RF emissions from the smart meter transmitter. Average and peak values were measured and recorded at each site, for reference. Silver Springs, manufacturer of the radio within the meter, stated that spurious peak readings could be caused in the near field due to the test equipment picking up reflections off the meter or other objects or noise by other RF sources. Therefore, the RMS readings are an industry standard measurement of the average continuous power density and best represents the effect of exposure over time to a human being. Report - Smart Meter RF Testing prepared by Cascadia PM April 2014 Page 6

7 Exposure significance The test results were taken under the worst conditions and therefore generated a conservative assessment of exposure by over-representing rather than under-representing the exposure over time. The meter was triggered to transmit continuously during testing. Normally, the meter transmits for 60 seconds every hour. The exposures allowable by the FCC are based on time, so the average RMS readings should be less than 1/60 th of the recorded readings when the meter is in the transmitting state. Moreover, the readings were compared to the IEEE Standard (0.6mW/cm 2 ) which is more than ten (10) times lower than the current Hawaii State occupational health and safety guidelines of (10mW/cm 2 ). Based upon these test results, the interpretation of the power density values with respect to a potential health hazard for workers and general population can now be readily assessed. The radiation being emitted by each of the five (5) smart meters are within the safe power density range covered by the IEEE Standard for general population and the State suggested guidelines of occupational conditions. The data collected during the pre and post activation survey of the area clearly indicated that the workers are not exposed to levels of radio frequency radiation higher than the IEEE Standard. The highest reading encountered in any location was.015% ( mw/cm 2 ) of the IEEE Standard maximum exposure level. These values are again below the most conservative standards published ( mW/cm 2 ) by the National Council on Radiation Protection 1. The values recorded do not constitute a hazard to the public, or to persons that are exposed as a consequence of their employment who may not be fully aware of the potential for exposure or cannot exercise control over their exposure. Referenced Exposure Guideline Standard-setting agencies in the U.S. and abroad have conducted independent surveys of the scientific literature to the end of recommending limits on exposure to RF fields. The National Council on Radiation Protection (NCRP), which was chartered by the U.S. Congress to develop exposure criteria for all forms of electromagnetic radiation, published an extensive review of the data based on biological effects of exposure to RF fields in The NCRP s Scientific Committee 53 made a distinction between occupational and general population exposures, which resulted in a two-tiered standard. The occupationally exposed worker (for example, an engineer or contractor installing or maintaining a radio transmitter) would be protected at the original ANSI-1982 limit on the SAR; no exposure in excess of 0.4 W/kg or 10 mw/cm 2. However, an additional five-fold reduction was recommended for members of the general population; no exposure in excess of 0.08 W/kg or 2 mw/cm 2. The NCRP s two-tier philosophy has been adopted by standard-setting bodies of many nationalities and by the International Radiation Protection Association (IRPA). The (1992) formulation of radio frequency exposure standards by the ANSI/IEEE has followed suit. In 1996, the National Council on Radiation Protection (NCRP) adopted new guidelines of compliance for human exposure to radiofrequency (RF) electromagnetic fields and published a new guidance document in Table 1 in appendix A of this document is reproduced below. 1 Evaluating Compliance with FCC Guidelines for Human Exposure to Radiofrequency Electromagnetic Fields, OET Bulletin 65, Edition 97-01, August Evaluating Compliance with FCC Guidelines for Human Exposure to Radiofrequency Electromagnetic Fields, OST Bulletin No. 65, October Evaluating Compliance with FCC Guidelines for Human Exposure to Radiofrequency Electromagnetic Fields, OET Bulletin 65, Edition 97-01,August Report - Smart Meter RF Testing prepared by Cascadia PM April 2014 Page 7

8 Table 1: LIMITS FOR MAXIMUM PERMISSIBLE EXPOSURE (MPE) NOTE 1: Occupational/controlled limits apply in situations in which persons are exposed as a consequence of their employment provided those persons are fully aware of the potential for exposure and can exercise control over their exposure. Limits for occupational/controlled exposure also apply in situations when an individual is transient through a location where occupational/controlled limits apply provided he or she is made aware of the potential for exposure. NOTE 2: General population/uncontrolled exposures apply in situations in which the general public may be exposed, or in which persons that are exposed as a consequence of their employment may not be fully aware of the potential for exposure or cannot exercise control over their exposure. Current Hawaii State occupational health and safety regulations allow workers to be exposed to 10 milliwatts per square centimeter (10 mw/cm 2 ) of electromagnetic radiation in the frequency range of 10 megahertz (MHz) to 100 gigahertz (GHz) as averaged during any 0.1-hour time period. The Hawaii State Occupational Safety and Health Standards (Title 12 sub-title 8, Part 8 Paragraph ) quoted in the previous paragraph are identical to the U.S. Department of Labor s criteria as promulgated by the Occupational Safety and Health Administration (OSHA). The Code of Federal Regulations (CFR Title 29, Parts are superseded in the State of Hawaii by the Hawaii State Department of Labor s criteria, but they are identical with one another. There are other guides, however, that are slightly more conservative and these are reviewed below. The American Conference of Governmental Industrial Hygienists (ACGIH) has published threshold Limit Values (TLVs) for a number of decades. Though they do not constitute federal, state, or other regulatory standards, they are nevertheless updated on an annual basis and are founded on verifiable scientific, medical, toxicological, and other technical reports and findings. The TLVs are used by professional industrial hygienists and cover both chemical substances and physical agents. In the case of radio frequency / microwave radiation, the ACGIH TLVs 4 refer to radiation in the frequency range from 30 kilohertz (khz) to 300 GHz, which covers a much broader range than the federal OSHA or Hawaii State regulations. Report - Smart Meter RF Testing prepared by Cascadia PM April 2014 Page 8

9 There are other standards generating organizations, but they do not recommend guides any different than those listed above. This is because they are all selected to limit the average whole body specific absorption rate (SAR) to 0.4 Watts per kilogram of body weight (W/kg) in any six-minute (0.1 hour) period of time for frequencies of 3 MHz to 300 GHz. This is a tenfold reduction below the consensus threshold of harm (4 W/kg) and the American National Standards Institute (ANSI) based their 1982 standard on this value. 5 Frequency Dependence of Effects The FCC exposure limit is frequency dependent. The maximum permissible exposure (MPE) limits depend upon the frequency of the signal to which a person is exposed because the human body absorbs energy differently at some frequencies than at others. Since the body absorbs FM radio signals between MHz more readily than MHz, the MPE level for signals from a smart meter is set at a higher maximum than the MPE for signals from a FM transmitter. The Chart 1 below graphically illustrates this point. Chart 1: FCC EXPOSURE LIMITS RELATIVE TO TRANSMITTED FREQUENCY Restating FCC Guidelines for Human Exposure to Radiofrequency Electromagnetic Fields, the maximum permissible exposure in the frequency range of 902 to 928 MHz is 0.6 milliwatts per square centimeter (0.6 mw/cm 2 ) as averaged during any 0.1-hour time period. 4 ACGIH 2001 adoption 5 Prior to 1988, C95 standards were developed by Accredited Standards Committee C95, and submitted to the American National Standards Institute (ANSI) for approval and issuance as ANSI C95 standards. Between 1988 and 1990, the committee was converted to Standards Coordinating Committee 28 (SCC 28) under the sponsorship of the IEEE Standards Board. In 2001, the IEEE Standards Association Standards Board approved the name International Committee on Electromagnetic Safety (ICES) for SCC 28 to better reflect the scope of the committee and its international membership. In accordance with policies of the IEEE, C95 standards are issued and developed as IEEE standards, as well as submitted to ANSI for recognition. Report - Smart Meter RF Testing prepared by Cascadia PM April 2014 Page 9

10 Conclusion Based on the foregoing, it is determined that the signal values measured do not create a hazard to the personnel working on the smart meter or to the general public who happen to pass the meter. The test results were taken under the worst conditions where the smart meter was transmitting. But in real operation, the meter is programmed to transmit only 60 seconds of a full hour. Considering the limited amount of actual signal transmission time, the low signal levels generated are conservative when you factor in the actual time the meter is transmitting a signal. The personnel working on or near the utility pole where the access point is installed are also not being exposed to levels of radio frequency radiation higher than the IEEE standard. Meter readings at no time exceeded.015% of the general population exposure standard. Should you have any questions or comments, please do not hesitate to contact us. Respectfully submitted, Reviewed and Approved, Cascadia PM, LLC Troy Thorhill Troy Thornhill Cascadia PM Matthew Miura Matthew K. Miura, PE Director - Cascadia PM Report - Smart Meter RF Testing prepared by Cascadia PM April 2014 Page 10

11 PRODUCT DATA SHEET Communications Module for Electricity Meters Adding twoway wireless communications to a broad array of meters: Offers one-watt transmitter to provide full, twoway wireless NAN communications Supports 2.4 GHz HAN communications Integrates with Silver Spring UtilityIQ application suite to support advanced metering and demand response Enables over-the-air firmware upgrades to reduce cost Provides full security and encryption to meet rigorous industry standards Smart Metering the Foundation of the Smart Grid The Silver Spring TM Smart Energy Platform combines network infrastructure, software, and professional services to enable a range of smart grid applications. Enabling two-way communications with next-generation electricity meters is fundamental to building the smart grid. The Silver Spring Communications Module integrates under glass inside partners electricity meters to provide wireless networking both back to the utility back office and into the customer s home. The module easily installs inside these meters and leverages Silver Spring network devices to form a highly resilient mesh network for the utility. The resulting two-way communications network gives utilities greater efficiency, more reliable service delivery, Utility Back-office Systems Silver Spring Message Bus Silver Spring Applications improved customer satisfaction, and a scalable platform for adding advanced smart grid applications both now and in the future. The Communications Module accesses demand, consumption, time-of-use and interval data, alarms, and power-quality data from the meter. Its two-way wireless functionality supports remote data acquisition, meter program management, and real-time asynchronous alerts for meter tampering or outages. Utilities can reprogram metering schedules over the air at any time for specific interval, register, or security reads, with access to both logged and instantaneous data. Depending upon the capabilities of the meter, utilities can also periodically monitor instantaneous voltage and temperature data. The Silver Spring Smart Energy Platform supports a range of smart grid applications on a single open standards-based network. UtilityIQ Unified Software GridScape Unified Management SilverLink Cloud Services CustomerIQ Customer Engagement WAN ACCESS POINT ETHERNET CELLULAR ACCESS POINT BRIDGE MASTER RELAY MICROMESH TECHNOLOGY LOAD CONTROL RELAY BRIDGE EVSE BRIDGE IEC METER GAS IMU ZIGBEE WATER FCI Advanced Metering Demand-side Management Distribution Automation About Silver Spring Networks Silver Spring Networks is a leading networking platform and solutions provider for smart energy networks. Our pioneering IPv6 networking platform, with 16.5 million Silver Spring enabled devices delivered, is connecting utilities to homes and business throughout the world with the goal of achieving greater energy efficiency for the planet. Silver Spring s innovative solutions enable utilities to gain operational efficiencies, improve grid reliability, and empower consumers to monitor and manage energy consumption. Silver Spring Networks is used by major utilities around the globe including Baltimore Gas & Electric, CitiPower & Powercor, Commonwealth Edison, CPS Energy, Florida Power & Light, Jemena Electricity Networks Limited, Pacific Gas & Electric, Pepco Holdings, Inc., and Progress Energy, among others. For more information please visit

12 PRODUCT DATA SHEET Communications Module for Electricity Meters With its full, one-watt transmitter, the Communications Module provides broad reach and robust connectivity in the Neighborhood or Field Area Network (NAN or FAN). In addition to supporting a 900 MHz radio for the NAN, the Communications Module also features an optional 2.4 GHz radio for the Home Area Network (HAN). This radio supports the ZigBee Smart Energy Profile specification to communicate with a wide range of smart devices within the home. Because the specification is evolving, Silver Spring designed its ZigBee radio with upgradable hardware to support more sophisticated protocol requirements. The Communications Module is available in a variety of NIC models to support the needs of disparate utilities and geographic regions. Features Full, two-way communications One-watt transmitter Frequency Hopping Spread Spectrum (FHSS) Robust security and encryption Dynamic network discovery and self healing Scheduled and on-demand meter reads Alarm detection and clearing Communications Module Specifications General: NIC 300 product family Platform NAN communications Architecture: System-on-Chip (SoC) Processor: SoC-based ARM7, adjustable frequencies RAM: 4 MB Flash: 8 MB Data rates: 100 kbps Spread spectrum: FHSS Transmitter output: 27 to 30 dbm (500 mw to 1 W) Receiver sensitivity: -97 dbm for 1% PER HAN communications Protocols: IEEE , ZigBee Smart Energy Profile 1.1 Frequency: 2.4 GHz ISM Band Transmitter output: 20 to 23 dbm (100 to 200 mw) Receiver sensitivity: -97 dbm for 1% PER Protocols / Security Environmental Addressing: IPv6 Encryption: Advanced Encryption Standard (AES-128 or AES-256) Security: Secure Hash Algorithm 256-bit (SHA-256) and RSA-1024 or ECC-256 Key storage: Secure NVRAM with tamper detection and key erasure Operating temperature: -40 C to +85 C (-40 F to +185 F) Humidity: 0% to 95%, non-condensing Communications Module Specifications North America: NIC 310 Radio Frequencies: MHz Approvals: FCC , Industry Canada RSS-210 Network time management Interfaces Meter: ANSI C12.18/C12.19, serial Continuous neighbor monitoring and route calculation Over-the-air firmware upgrades and meter programming Power outage and restoration notification Support for a wide range of meters and forms Meters supported GE I GE I-210+c 1 GE kv2c 1 GE kv2c+ 1 2 L+G E330 FOCUS AX L+G E350 AX-SD Single Phase L+G E330 FOCUS AX Polyphase L+G E650 S4e Elster A3 ALPHA 1 Denotes Measurement Canada approval 2 Supported via External Communications Module NIC 310 and 310x

13 PRODUCT DATA SHEET Communications Module for Electricity Meters Communications Module Specifications Australia: NIC 320 Radio Frequencies: MHz Approvals: AS/NZS 4268 Interfaces Meters supported Secure i-credit 500 Secure Sprint 200 Secure Premier L+G E L+G E L+G E L+G E Meter: ANSI C12.18/C12.19, serial External: Optional serial communications port NIC 320 Communications Module Specifications Brazil: NIC 330 Radio Interfaces Meters supported Frequencies: MHz, MHz Approvals: ANATEL Meter: ANSI C12.18/C12.19, serial Nansen Spectrum M Nansen Spectrum K Elster A3 NIC 330 family, with 330e and 330x models Communications Module Specifications General: NIC 400 product family Platform NAN communications Architecture: ARM based SoC RAM: 4 MB Flash: 8 MB Data rates: 50 kbps to 300 kbps Spread spectrum: FHSS Transmitter output: 27 to 30 dbm (500 mw to 1 W) Receive sensitivity: Data Rate (kbps) Receive Sensitivity (dbm for 10% PER) Protocol: IEEE g NIC 400 HAN communications Protocols: IEEE , ZigBee Smart Energy Profile 1.1 Frequency: 2.4 GHz ISM Band Transmitter output: 20 to 23 dbm (100 to 200 mw) Receiver sensitivity: -97 dbm for 1% PER Protocols / Security Environmental Addressing: IPv6 Encryption: Advanced Encryption Standard (AES-128 or AES-256) Security: Secure Hash Algorithm 256-bit (SHA-256) and RSA-1024 or ECC-256 Key storage: Secure NVRAM with tamper detection and key erasure Operating temperature: -40 C to +85 C (-40 F to +185 F) Humidity: 0% to 95%, non-condensing

14 PRODUCT DATA SHEET Communications Module for Electricity Meters Communications Module Specifications North America: NIC 400 Series Radio Interfaces Frequencies: MHz Approvals: FCC , Industry Canada RSS-210 Meter: ANSI C12.18/C12.19, serial Meters supported Elster A3 Itron CENTRON II C L+G E330 FOCUS AX L+G E350 AX-SD Single Phase L+G E330 FOCUS AX Polyphase 1 Denotes Measurement Canada approval Communications Module Specifications Australia/New Zealand NIC 400 Series Radio Interfaces Frequencies: Australia: MHz New Zealand: MHz Approvals: AS/NZS 4268 Meter: ANSI C12.18/C12.19, serial External: Optional serial communications port Meters supported L+G E L+G E L+G E L+G E Communications Module Specifications Brazil: NIC 400 series Radio Interfaces Meters supported Frequencies: MHz, MHz Approvals: ANATEL Meter: ANSI C12.18/C12.19, serial, DLMS-COSEM Itron SL7000 Meter Patch Antenna Coupler Physical Interfaces Environmental Antenna connector: N Type, Female Antenna types: Various Cable length: cm (6 ) Operating temperature: -40 C to +85 C (-40 F to +185 F) Humidity: 0% to 95%, non-condensing Approvals FCC: The optional Meter Patch Antenna Coupler connects meters equipped with a Communications Module to an external antenna for greater signal range and coverage. silverspringnet.com Copyright 2013 Silver Spring Networks. All Rights Reserved. All trademarks are the properties of their respective owners. REV. 6/19/2013

15 Test Result Sheets of Smart Meter RF Testing Maui Prepared by CASCADIA PM, LLC

16 Typical Radio Frequency Signal Power Density measurements in actual conditions Bar Chart Comparison FCC Standard 600 uw/cm 2 Smart Meter at 10 feet away FM radio/tv broadcast Wi Fi Router at 3 feet away Smart Meter at 3 feet away Microwave oven 2 feet away Cell phone at your ear 500 1,000 1,500 2,000 2,500 3,000 3,500 4,000 4,500 5,000 Notes: Measured in microwatts/cm 2

17 LOCATION 1 Date 2/20/2014 Address 3043 Mapu Place City, Island Kihei, Maui Latitude/Longitude ', '

18 SMART METER RF TEST FORM Test Number M 1001 Date 2/20/2014 Address 3043 Mapu Place City, Island Kihei, Maui Latitude/Longitude ', ' Time 9:30 a.m. Tax Map Key :018 Ground Level 315' AMSL Antenna Tip Height 6' 3" AGL Smart Meter Make GE I 210 Model NIC 314 Serial Number Meter Transmision Level Measurement Horizontal Orientation Vertical Orientation OFF or PRE µw/m 2 ON or POST µw/m 2 OFF or PRE µw/m 2 ON or POST µw/m 2 FCC Limit µw/m 2 Peak Average Peak Average Peak Average Peak Average Average Test Location 1 At Meter Test Location 2 5 feet away from meter Test Location 3 20 feet away from meter Test Location 4 50 feet away from meter Qualitative Description Test locations 3 and 4 were made from adjacent property and were barely obstructed by plants/trees Several readings were higher due to stray interferrence when testing close to the wall. Test Equipment Manufacturer Gigahertz Solutions Make Serial Number HF Calibration Date Serial Number ANT HF 35C 2/19/2014 Tested by Troy Thornhill Certified by Matt Miura

19 LOCATION 2 Date 2/20/2014 Address 627 Kupulau Drive City, Island Kihei, Maui Latitude/Longitude ', '

20 SMART METER RF TEST FORM Test Number M 1002 Date 2/20/2014 Address 627 Kupulau Drive City, Island Kihei, Maui Latitude/Longitude ', ' Time 12:00 p.m. Tax Map Key :022 Ground Level 481' AMSL Antenna Tip Height 6' 3" AGL Smart Meter Make GE I 210 Model NIC 314 Serial Number Meter Transmision Level Measurement Horizontal Orientation Vertical Orientation OFF or PRE µw/m 2 ON or POST µw/m 2 OFF or PRE µw/m 2 ON or POST µw/m 2 FCC Limit µw/m 2 Peak Average Peak Average Peak Average Peak Average Average Test Location 1 At Meter Test Location 2 5 feet away from meter Test Location 3 20 feet away from meter Test Location 4 50 feet away from meter Qualitative Description Test locations 3 and 4 were made from adjacent property and terrain elevation changed/increased slightly Several readings were higher due to stray interferrence when testing close to the wall. Test Equipment Manufacturer Gigahertz Solutions Make Serial Number HF Calibration Date Serial Number ANT HF 35C 2/19/2014 Tested by Troy Thornhill Certified by Matt Miura

21 LOCATION 3 Date 2/20/2014 Address 3288 Keha Drive City, Island Kihei, Maui Latitude/Longitude ', '

22 SMART METER RF TEST FORM Test Number M 1003 Date 2/20/2014 Address 3288 Keha Drive City, Island Kihei, Maui Latitude/Longitude ', ' Smart Meter Make GE I 210 Model NIC 314 Serial Number Meter Transmision Level Measurement Horizontal Orientation Vertical Orientation OFF or PRE µw/m 2 ON or POST µw/m 2 OFF or PRE µw/m 2 ON or POST µw/m 2 FCC Limit µw/m 2 Peak Average Peak Average Peak Average Peak Average Average Test Location 1 At Meter Test Location 2 5 feet away from meter Test Location 3 20 feet away from meter Test Location 4 50 feet away from meter Qualitative Description Location 4 was tested from street Location 3 and 4 were barely obstructed by plants/trees and terrain elevation increased slightly Several readings were higher due to stray interferrence when testing close to the wall. Test Equipment Manufacturer Gigahertz Solutions Make Serial Number HF Calibration Date Serial Number ANT Time 12:30 p.m. Tax Map Key :049 Ground Level 593' AMSL Antenna Tip Height 6' 3" AGL HF 35C 2/19/2014 Tested by Troy Thornhill Certified by Matt Miura

23 LOCATION 4 Date 2/20/2014 Address 539 Pawali Street City, Island Kihei, Maui Latitude/Longitude ', '

24 SMART METER RF TEST FORM Date 2/20/2014 Address 539 Pawali Street City, Island Kihei, Maui Latitude/Longitude ', ' Test Number Time Tax Map Key Ground Level Antenna Tip Height M :15 p.m : ' AMSL 6' 3" AGL Smart Meter Make GE I 210 Model NIC 314 Serial Number Meter Transmision Level Measurement Horizontal Orientation Vertical Orientation OFF or PRE ON or POST OFF or PRE ON or POST µw/m 2 µw/m 2 µw/m 2 µw/m 2 FCC Limit µw/m 2 Peak Average Peak Average Peak Average Peak Average Average Test Location 1 At Meter Test Location 2 5 feet away from meter Test Location 3 20 feet away from meter Test Location 4 50 feet away from meter Qualitative Description Test locations 3 and 4 were made from adjacent property and were obstructed by plants/trees Several readings were higher due to stray interferrence when testing close to the wall. Test Equipment Manufacturer Gigahertz Solutions Make Serial Number HF Calibration Date Serial Number ANT HF 35C 2/19/2014 Tested by Troy Thornhill Certified by Matt Miura

25 LOCATION 5 Date 2/20/2014 Address 1148 Kupulau Drive City, Island Kihei, Maui Latitude/Longitude ', '

26 SMART METER RF TEST FORM Test Number M 1005 Date 2/20/2014 Address 1148 Kupulau Drive City, Island Kihei, Maui Latitude/Longitude ', ' Smart Meter Make GE I 210 Model NIC 314 Serial Number Meter Transmision Level Measurement Horizontal Orientation Vertical Orientation OFF or PRE µw/m 2 ON or POST µw/m 2 OFF or PRE µw/m 2 ON or POST µw/m 2 FCC Limit µw/m 2 Peak Average Peak Average Peak Average Peak Average Average Test Location 1 At Meter Test Location 2 5 feet away from meter Test Location 3 20 feet away from meter Test Location 4 35 feet away from meter Qualitative Description Test locations 3 and 4 were made from the left of the meter due to space constrictions Location 4 was measured from only 35' and not 50' due to space constrictions Several readings were higher due to existing stray interferrence when testing close to the wall. Test Equipment Manufacturer Gigahertz Solutions Make Serial Number HF Calibration Date Serial Number ANT Time 4:00 p.m. Tax Map Key :073 Ground Level 636' AMSL Antenna Tip Height 6' 0" AGL HF 35C 2/19/2014 Tested by Troy Thornhill Certified by Matt Miura

27 LOCATION 6 Date 2/20/2014 Address near 1060 Kupulau Drive City, Island Kihei, Maui Latitude/Longitude ', '

28 SMART METER RF TEST FORM Test Number AP 1001 Date 2/20/2014 Address near 1060 Kupulau Drive City, Island Kihei, Maui Latitude/Longitude ', ' Access Point Make n/a Model n/a Serial Number n/a Antenna Transmision Level Measurement Horizontal Orientation Vertical Orientation Note: Access point is continually trasmitting (no OFF or PRE tests available) FCC Limit µw/m 2 µw/m 2 µw/m 2 Peak Average Peak Average Average Test Location 1 At Access Point not taken not taken not taken not taken 100,000,000 Test Location 2 5 feet away from antenna ,000,000 Test Location 3 20 feet away from antenna ,000,000 Test Location 4 50 feet away from antenna ,000,000 Qualitative Description Test Equipment Manufacturer Gigahertz Solutions Make Serial Number HF Calibration Date Serial Number ANT Time Tax Map Key Ground Level Antenna Tip Height This sheet represents the measurements taken at the access point antenna (not at a smart meter) Measurements taken from "cherry picker" bucket approx. 40' in the air This site evaluated under the higher 'occupational' FCC standards HF 35C 2/19/2014 1:10 p.m. n/a 701' AMSL Approx. 40' AGL Tested by Troy Thornhill Certified by Matt Miura