For further information, please contact Geoff Higgins at or by at

Transcription

1 C5-3 Janet Fraser Chief Regulatory Officer Phone: Fax: November 23, 2012 Mr. Dennis Swanson Director, Regulatory Affairs Regulatory Affairs Department Suite 100, 1975 Springfield Road Kelowna, BC V17 7V7 Via Dear Mr. Swanson: RE: Project No Application for a Certificate of Public Convenience and Necessity for the Advanced Metering Infrastructure Project British Columbia Hydro and Power Authority (BC Hydro) Round 2 Information Request Please find attached BC Hydro s Information Request to for the above noted proceeding. For further information, please contact Geoff Higgins at or by at bchydroregulatorygroup@bchydro.com. Yours sincerely, Janet Fraser Chief Regulatory Officer cf/tn Enclosure Copy to: British Columbia Utilities Commission Attention: Ms. Erica Hamilton Commission.Secretary@bcuc.com BCUC Project No ( Advanced Metering Infrastructure CPCN) Registered Intervener Distribution List British Columbia Hydro and Power Authority, 333 Dunsmuir Street, Vancouver BC V6B 5R3

2 British Columbia Hydro and Power Authority Project No Application for a Certificate of Public Convenience and Necessity for the Advanced Metering Infrastructure Project 1.0 Reference: CSTS IR FortisBC response says: Safety Code 6 is a legally binding standard in Canada. The basis and provisions of Safety Code 6 are similar to standards developed by many other national and international scientific, health, and governmental agencies. 1.1 Please confirm that Safety Code 6 refers to the Health Canada Safety Code 6, Limits of Human Exposure to Radiofrequency Electromagnetic Fields in the Frequency Range from 3 khz to 300 GHz, issued by Health Canada in 1999, and updated by Health Canada in Please confirm that the Preface section of Safety Code 6 (2009) indicates that the code establishes safety limits for human exposure to RF in the frequency range from 3 khz to 300 GHz, that these safety limits apply to all individuals working at or visiting federally regulated sites, and that the code has been adopted as the scientific basis for the equipment certification specifications outlined in Industry Canada s regulatory compliance documents that govern the use of wireless devices in Canada, such as cell phones, cell towers (base stations) and broadcast antennae. 1.3 Please confirm that the federal government sets technical requirements and standards for radio apparatus, interference-causing equipment and radio-sensitive equipment in Canada under s. 5(1)(d) of the Radiocommunication Act, and that s. 2.1 of the Radiocommunication Regulation specifies that the standards are set out in the Category I Equipment Standards List and the Category II Equipment Standards List, both as amended from time to time, and both published by the Department of Industry. 1.4 Please confirm that the Category I Equipment Standards List and the Category II Equipment Standards List both include Radio Standards Specifications (RSS) 102, Radio Frequency (RF) Exposure Compliance of Radiocommunication Apparatus (All Frequency Bands) Please confirm that RSS 102 sets out the requirements used to evaluate RF exposure compliance of radiocommunication apparatus designed to be used within the vicinity of the human body, including mobile, portable and fixed transmitters having an Page 1 of 9

3 integral antenna, systems requiring licensing with detachable antennas sold with the transmitters, or licence-exempt transmitters with detachable antennas as defined in RSS-Gen Please confirm that RSS 102 states that proponents and operators of antenna system installations are responsible for ensuring that all radiocommunication and broadcasting installations comply at all times with Safety Code 6; and that section 4 of RSS-102 states that for the purpose of this standard [RSS-102], Industry Canada has adopted the SAR and RF field strength limits established in Health Canada s RF exposure guideline, Safety Code Please confirm that section 7.23 of B.C. s Occupational Health and Safety Regulation requires that equipment producing radiofrequency must be installed, operated and maintained in accordance with Health Canada Safety Code 6, Limits of Human Exposure to Radiofrequency Electromagnetic Fields in the Frequency Range from 3 khz to 300 GHz, 1999, as amended from time to time. 1.6 Please confirm whether FortisBC s AMI program will comply with Safety Code Please confirm that the radio frequency exposure from a smart meter, measured as specified by Safety Code 6, should take duty cycle into account. 1.8 Please provide the maximum radio frequency exposure from a FortisBC smart meter based on Safety Code 6 measurement standards that properly account for the duty cycle. 2.0 Reference: CSTS IR and BCRUCA IR1 7.1 FortisBC response says: In matters related to health, FortisBC relies on the expertise of the Provincial Health Officer, Health Canada, and World Health Organization, who have all confirmed that wireless meters pose no known health risk or reason for concern. In situations requiring accommodation, FortisBC will assess extenuating circumstances for individual customers on a case-by-case basis. 2.1 Please provide the Statement of the Chief Medical Health Officer of British Columbia, dated June 2011, regarding health concerns about cellular phone transmission antennae and base stations, located at: Please confirm that the conclusion of this Statement found on page 5 states: As has Health Canada, the Chief Medical Health Officer concludes that, in light of the current scientific understanding of the risks of RF exposures to the public, the installation of base Page 2 of 9

4 stations and cellular antennae in the community do not pose an adverse health risk and Safety Code 6 provides an appropriate level of protection. 2.2 Please provide the test results from the BC Centre for Disease Control titled Measurement of Radiofrequency (RF) Emissions from BC Hydro s Itron Smart Meters located at: ements.pdf 2.3 Please provide letter of advice to Richmond Council on Smart Meters from the Vancouver Coastal Health dated December 20, 2011 and located at: Please confirm that this letter concludes with the following statement: In conclusion, the public may be opposed to the BC Hydro Smart Meter Program for a number of reasons. That these Smart Meters are health hazards should not be one of them. These devices are active only for an extremely short amount of time each day. They add so little to the existing background radio-frequency fields that it is very difficult to separate them apart from our everyday environment. We recognize that some may disagree with our assessment. We respectfully differ. We are confident however that our assessment is in agreement with the overall scientific understanding regarding radio frequency electromagnetic fields. 2.4 Please provide Health Canada s Smart Meters Update dated December 2011 and located at: Please confirm this Update states on page 2: Since RF energy exposure levels are far below Canadian and international safety limits, Health Canada does not consider that any precautionary measures are needed to reduce RF energy exposure from smart meters. Page 3 of 9

5 2.5 Please provide the Smart Meter and Cancer Risk Statement of the British Columbia Ministry of Health, dated December 23, 2011, located at: Please confirm that this Statement of the British Columbia Ministry of Health states: Smart Meters emit RF radiation, but only intermittently, and at a level several times below that of the highest level of personal exposures from cell phones, and well below existing limits for RF exposure to the public. Smart Meters generate an RF signal an average of only one minute per day. In addition, Smart Meters emit very low power about one watt. This is less than 2 microwatts per square centimetre (μw/cm 2 ) when standing adjacent to the meter. A microwatt is one millionth of a watt. And, exposure to RF drops quickly with distance from the device. Three meters (10 feet) from the smart meter, the radio frequency signal drops to less than per cent (0.005 μw/cm 2 ) of the Health Canada exposure limits. This exposure level is much less than exposure to RF from cell phone use Please confirm that this Statement of the British Columbia Ministry of Health states: The evidence, therefore, does not support a conclusion that RF fields, whether from cell phones or Smart Meters, can cause brain tumours in adults. 2.6 Please provide the World Health Organization backgrounder dated December 2005 and found at: Please confirm that this World Health Organization backgrounder states: EHS [Electromagnetic hypersensitivity] is characterized by a variety of non-specific symptoms that differ from individual to individual. The symptoms are certainly real and can vary widely in their severity. Whatever its cause, EHS can be a disabling problem for the affected individual. EHS has no clear diagnostic criteria and there is no scientific basis to link EHS symptoms to EMF exposure. Further, EHS is not a medical diagnosis, nor is it clear that it represents a single medical problem. Page 4 of 9

6 2.7 Please provide the January 10, 2011 article from the New York Times titled Health Concerns Over 'Smart' Electric Meters Gain Traction in Calif. located at: Please confirm the following quote from Daniel Epstein, spokesperson for World Health Organization in Americas region is contained in this New York Times article: The World Health Organization is concerned about cell phones, but not smart meters. "It sort of sounds, I wouldn't say specious, but far-fetched, really," said Daniel Epstein, spokesman for the WHO's Americas region. "If the U.S. or some other country wanted help with that, we'd provide some expertise, but this is not really an issue on our radar at all, with all the major public health problems that we have." A review of the literature on cell phone use is due out sometime this year, he said, and a 2007 WHO review found that lowfrequency electromagnetic fields in general are not associated with cancer, depression, suicide, cardiovascular disorders, reproductive dysfunction, developmental disorders, immunological modifications, neurobehavioral effects or neurodegenerative disease. In the case of childhood leukemia, which has been found to have a positive association with low-frequency fields, WHO did not find a causal relationship. 2.8 Please provide the report titled U Report to the Commission prepared by staff of the Michigan Public Service Commission dated June 29, 2012, Case No. U found at: Please confirm the Executive Summary (on page 2) of this report states: After careful review of the available literature and studies, the Staff has determined that the health risk from the installation and operation of metering systems using radio transmitters is insignificant. In addition, the appropriate federal health and safety regulations provide assurance that smart meters represent a safe technology. Page 5 of 9

7 2.9 Please provide the April 2011 study on the health impacts of RF affects from Smart Meters titled Health Impacts of Radio Frequency Exposure from Smart Meters by the California Council on Science and Technology, located at: Please confirm that the key report findings, found on page 4, are: 1. Wireless smart meters, when installed and properly maintained, result in much smaller levels of radio frequency (RF) exposure than many existing common household electronic devices, particularly cell phones and microwave ovens. 2. The current FCC standard provides an adequate factor of safety against known thermally induced health impacts of existing common household electronic devices and smart meters. 3. To date, scientific studies have not identified or confirmed negative health effects from potential non thermal impacts of RF emissions such as those produced by existing common household electronic devices and smart meters. 4. Not enough is currently known about potential non thermal impacts of radio frequency emissions to identify or recommend additional standards for such impacts 2.10 Please provide the March 2011 report titled A Discussion of Smart Meters and RF Exposure Issues publish by the Edison Electric Institute, located at: Please confirm the report stated in the Executive Summary (page 3): All smart meter radio devices must be certified to the FCC s rules. Tests simulating multi-family metering locations containing several meters in close proximity have shown RF exposure levels dramatically less than FCC limits. The FCC limits on maximum permissible exposure (MPE) for application to the general public were set using safety factors fifty times lower than the levels of known effects. Exposure levels drop significantly (1) with the distance from the transmitter, (2) with spatial averaging, and (3) in living spaces due to the attenuation effects of building materials. Due to shielding of the meter enclosure and signal Page 6 of 9

8 patterns, RF exposure from the rear of a metering location is nominally 10 times less than in front of the meter and dramatically below FCC limits, not including the spatial averaging and building material attenuation reductions. 2 For measurement and calculation purposes some studies use a 100% duty cycle parameters. However, the maximum operational Duty Cycle for Smart meter systems is less than 50% to prevent message traffic congestion and collisions. The typical Duty Cycles for Smart Meter Systems is between 1% and 5%. An RF exposure comparison of a person talking on a cell phone and a person 3 and 10 feet from a continuously operating Smart Meter would result in Smart Meter RF exposure 125 to 1250 times less than the cell phone. 3 In test environments simulating operational conditions, for power (250 mwatt - 2 Watt), duty cycle (2%-5%) at close distance (1 foot) from in front of the transmitter, Smart Meters produce very low RF exposure to the consumer, typically well under 10 % of the FCC exposure regulations Please provide the Electric Power Research Institute (EPRI) 2010 technical report titled An Investigation of Radiofrequency Fields Associated with the Itron Smart Meter located at: &parentname=objmgr&parentid=2&control=setcommunity&communityi D=221&PageIDqueryComId=0 If this link does not work, the report may be obtained by searching by the report title at EPRI s home page found at: Please confirm that on page 1-5 this report states: A detailed evaluation of possible RF fields produced by the Itron meters included in this study shows that regardless of duty cycle values for end point and cell relay meters, typical exposures that result from the operation of Smart Meters are very low and comply with scientifically based human exposure limits by a wide margin Please provide C IEEE Standard for Safety Levels with Respect to Human Exposure to Radio Frequency Electromagnetic Fields, 3 khz to 300 GHz located at: Page 7 of 9

9 2.13 Please provide the report from International Commission on Non-Ionizing Radiation Protection (ICNIRP) titled Exposure to high frequency electromagnetic fields, biological effects and health consequences (100 khz-300 GHz) located at: Reference: Appendix of CSTS IR1 59.4, BCSEA IR Please provide the report from IEEE Working Group dated September 2010 titled Coexistence analysis of IEEE Std with other IEEE standards and proposed standards. found at: coexistence-analysis.pdf 3.2 Please confirm that the IEEE working group states on page 2: While not required by this standard, IEEE devices can be reasonably expected to coexist, that is, to operate in proximity to other wireless devices. 4.0 Reference: CSTS IR The position of a limited number of scientists who have been most vociferous in advocating a contrary position is summarized in the 2007 Bioinitiative report ( 4.1 Please provide a copy of the report from Health Council of Netherlands dated September 2008 that analyzed the scientific value of the BioInitiative report, found at: Please confirm that the Health Council of Netherlands concluded on page 4 that: In view of the way the BioInitiative report was compiled, the selective use of scientific data and the other shortcomings mentioned above, the Committee concludes that the BioInitiative report is not an objective and balanced reflection of the current state of scientific knowledge. Therefore, the report does not provide any grounds for revising the current views as to the risks of exposure to electromagnetic fields. Page 8 of 9

10 4.2 Please provide a copy of the report from European Commission Joint Research Centre EMF-Net, date October 30, 2007, that analyzed the scientific value of the BioInitiative report, and found at: health/exposure_health_impact_met/emf-net/docs/efrtdocuments/emf- NET%20Comments%20on%20the%20BioInitiative%20Report%2030OCT 2007.pdf Please confirm that the European Commission Joint Research Centre concluded on page 1 that: None of these conclusions [of the Bio Initiative Working Group Report] is supported by the major national or international reviews as listed in Annexes 1 and 2, that have made use of the internationally accepted weight-of-evidence approach to study results. 4.3 Please provide a copy of the report dated December 18, 2008 from the Australian Centre for Radiofrequency Bioeffects Research on the scientific validity of the BioInitiative report, found at: c% pdf Please confirm that the Australian Centre for Radiofrequency Bioeffects Research states with respect to the BioInitiative report: Overall we think that the BioInitiative Report does not progress science, and would agree with the Health Council of the Netherlands 2 that the BioInitiative Report is not an objective and balanced reflection of the current state of scientific knowledge (page 4). As it stands it merely provides a set of views that are not consistent with the consensus of science, and it does not provide an analysis that is rigorous-enough to raise doubts about the scientific consensus. Page 9 of 9