20230731Petition for Reconsideration_Attachments.pdf

RECEIVED
2023 JULY 31, 2023 8:00AM
IDAHO PUBLIC
UTILITIES COMMISSION
PETITION FOR RECONSIDERATION
To: Jan Noriyuki, Commission Secretary
Idaho Public Utilities Commission
PO Box 83720
Boise, ID 83720-0074
Date: July 28, 2023
From: Samuel and Peggy Edwards
333 Shoshone Ave
Rexburg, Idaho 83440
RE : Petition to Reconsider Idaho Public Utilities Commission Final Order of Case JD "PAC-E-23-
05" issued on 11 July 2023
Dear Ma'am,
We petition for reconsideration ofldaho Public Utilities Commission's Final Order
dismissing our complaint (case ID "PAC-E-23-05"). Since the Commission packaged six different
complaints submitted from six individual situations, a single Final Order has been issued which
overlooks material substance of our Complaint. Did the Commission read the amicus brief
referenced in my Complaint? This 2021 evidence was provided to the Pennsylvania Supreme
Court to advocate for reasonable accommodation for those electro-sensitive persons who must
otherwise suffer deleterious harm as with our special needs daughter or with the case of Judy
Twede (ID PAC-E-23-06) or sell their house as with the case of Karen Lane (ID PAC-E-23-07).
Legal Clarification:
The Commission finds that "refusing to allow the Company 's representatives access to
replace existing meters with advanced metering infrastructure (AMI) meters is a violation of [ESR
No. 6(2)(d)] agreed to as a condition ofreceiving the Company's service." Is declining
replacement of our meter with a meter of substantively different capability equivalent to denying
access to the meter, per UCRR 302? Where is the law that authorizes ROCKY MOUNTAIN
POWER/PACIFICORP to disconnect our electric power?
We contest that the AMI meters represent a substantive change of metering capability to
r,esidents' electric meters, and that changes of capability are different in nature from the activities
of "furnish and maintain all meters and metering equipment". Whereas AMI advances certain
advanced wireless and monitoring capabilities, smart meters lack surge protection and from this
perspective must be recognized as a downgrade when compared to electromechanical metering. In
our case, the AMI initiative would be a change of metering capability against our will,
demonstrating that residents have no recognized voice in the metering technology that is attached
to our home.
By allowing no opt-outs in Idaho, AMI meters are not just an allowance, but a requirement
for utility service. Qui bona: who benefits from requiring l 00% of Idahoans to receive their
electric utilities through AMI meters? Why is 99.812% voluntary AMI upgrades (as reported in
ROCKY MOUNTAIN POWER/PACIFICORP "Motion to Dismiss") not "just and reasonable"
benefit to Company profit motives (efficiencies) and public infom1ation benefits so that the
Commission must ignore the safety, health, comfort and convenience of a tiny minority of the
public? By not allowing opt-out, the Commission has made disconnection the only option for a
medically sensitive minority of the public, as emphasized by the Company. (see Final Order, pg 4)
Evidence of a legitimate safety concern:
"The Commission is once again asked to weigh ... the claims presented in the Complaints."
Since the Commission has "reviewed the record, the arguments of the parties, and all submitted
materials" and yet "finds that the Complainants have not provided evidence to support a finding
that AMI meters present a legitimate safety concern," therefore we infer that the Commission does
not read references and provides only summary consideration of our Complaints: just under a page
in the Final Order, as compared with three pages reviewing the Company's Answer.
The aforementioned amicus brief is therefore enclosed as an addendum to this petition for
reconsideration. It has been referenced (as a footnote) in multiple of our previous communications
and expresses several salient facts and inferences regarding safety concerns which justify a
reasonable accommodation from the AMI initiative. A more complete list of published research
findings pertaining to AMI metering was included in our letter to Mr. Gary Hoogeveen (Rocky
Mountain Power CEO) of 02/16/2023 which was included with our Complaint.
• On August 13, 2021, a divided D.C. Circuit panel found that the FCC's decision not
to revisit its 1996 limits on Radio Frequency (RF) exposure was "arbitrary and
capricious" because it did not adequately respond to evidence in the administrative
record to determine whether the FCC 's guidelines "adequately protect against the
harmful effects of exposure to radiofrequency radiation unrelated to cancer."
(USCA Case #20-1025, aka Guidelines Remand)
• FCC guidelines cannot be a basis for any conclusions regarding RF safety including
for smart meters. No proper review was conducted by any of the responsible federal
agencies regarding non-cancer harm from exposure to radiation levels below the
FCC's guidelines. (Amicus Brief, pg 11)
• The human body responds to pulsed RF radiation, even at non-thermal levels.
Doctors routinely use pulsed RF/EMF for medical treatment and chronic exposure
can lead to significant health problems, including oxidative stress. (ibid, pp 13-14)
• FCC has also admitted there are neurological harms from RF exposures, at least in
the range of 3 Hz and 10 MHz, including adverse neural stimulation effects such as
perception of tingling, shock, pain, or altered behavior. "These harms occur
instantaneously, which means the FCC 's current method of averaging exposure
levels over 30 minutes -which completely obscures pulsation effects -is entirely
inappropriate." (ibid, pp 140-141)
• Pulsed RF emissions from the smart meter's transmitting antenna not only enter the
house wirelessly but also enter into and are conducted along the house's electrical
wiring. Other RF frequencies besides the RFs from the transmitting antennas also
enter the house electric system. These RFs are a byproduct of the AC/DC
conversion process done in the Switch Mode Power Supply (SMPS). Pulses can
occur up to 150,000 times per second ( or 150 KHz), creating observed noise spikes
imposed on the 60 Hz house electricity wave. These frequencies are present all the
time but are worse when less electricity is being used and when the smart meter
needs more power (e.g. during RF transmissions). Smart and digital meters create
pulsed RF emissions transmitted through the entire home's electric system. (ibid, pp
174-175)
• "Unlike wireless smart meters and digital meters, analog meters do not contain an
SMPS or other electronic components that create unintended RF frequencies . No
AC/DC conversion is necessary, and unlike smart and digital meters, analog meters
2
(<$100 value) have a separate wired grounding rod that eliminates much of the
"noise" that may come from the energy feed." (ibid, pp 176-177)
• Over 90% of studies on RF and oxidative stress have established that indeed
exposure to RF/EMFs (Electro-magnetic fields) induces an increase in free radicals,
and chronic exposure causes oxidative stress which leads to several adverse health
effects: disease, dysfunction, including electro-sensitivity, cancer, and DNA
damage. (ibid, pg 145)
• "Anyone who claims smart meters cannot produce the symptoms described by the
customers is ignorant of the FCC 's recent admission. They either do not understand
or are misrepresenting the science on biological and adverse effects from pulsed
RF/EMF. Many have reported getting ill following the installation of these smart
meters. Considering the way smart meters operate and the multitude of complex
emissions they create, it is no wonder. Forcing these meters on people who have
become affected by RF/EMF is unconscionable. Those with Electro-sensitivity and
others who are affected by RF/EMF must be allowed to secure analog meters
because it is the only type of meter th'at does not cause or worsen their condition."
(ibid, pg 160)
• See also discussions covering "federal government recognizes electro-sensitivity;
federal and state law requires effectiye accommodation" (ibid, pp 20-27) and that
the "only reasonable and effectj.ve accommodation is analog meter." (ibid, pp 31-
33)
Where there is danger, there must be choice, We call upon the Commission to offer a
reasonable accommodation t; objecting customers in the form of an electromechanical meter
(value <$100). Specifically, we petition that ROCKY MOUNTAIN POWER/ PACIFICORP be
ordered to replace our digital meter with an electrom.echanical meter.
Thank you for granting some of the relief requested in our Objection by declining ROCKY
MOUNTAIN POWER/PACIFICORP's motion to dismiss our case "with prejudice". We asked the
other Complainants to not file a petition for reconsideration to reduce the confusion or
generalization which has been caused while the Commission simultaneously considered multiple
Complaints. Other Complainants with whom we've been able to speak are also interested in a clear
response to a single Petition for Reconsideration. We hope that the Commission will now answer
our Legal question and carefully review the evidence provided which supports "a finding that AMI
meters present a legitimate safety concern, and that public utilities in Idaho should be required to
provide an opt-out option for AMI eters."
Very truly,
Samuel Z. Edwards, Sui Juris
Witness to signature # 1
3
IN THE SUPREME COURT OF PENNSYLVANIA MIDDLE DISTRICT
Appellee v. PENNSYLVANIA PUBLIC UTILITY
COMMISSION,
: : : : :
:
Appellee v. PENNSYLVANIA PUBLIC UTILITY COMMISSION,
: : : : : :
ALBRECHT, Appellees v. PENNSYLVANIA PUBLIC UTILITY COMMISSION,
: : : : : :

v. PENNSYLVANIA PUBLIC UTILITY COMMISSION APPEAL OF: PECO ENERGY
:
: : : : : :

LAURA SUNSTEIN MURPHY v. PENNSYLVANIA PUBLIC UTILITY COMMISSION APPEAL OF: PECO ENERGY
: : : : : : :
ALBRECHT v. PENNSYLVANIA PUBLIC UTILITY COMMISSION
APPEAL OF: PECO ENERGY
: : : : : : :
:
Cross-Appellant v. PENNSYLVANIA PUBLIC UTILITY COMMISSION, Appellee
: : : : : : :
Cross-Appellant v. PENNSYLVANIA PUBLIC UTILITY COMMISSION,
: : : : : :

CYNTHIA RANDALL AND PAUL ALBRECHT, Cross-Appellants v. PENNSYLVANIA PUBLIC UTILITY COMMISSION,
: : : : : :
Cross-Appellant v. PENNSYLVANIA PUBLIC UTILITY COMMISSION, PECO ENERGY COMPANY,
: : : : : :
Cross-Appellant
v. PENNSYLVANIA PUBLIC UTILITY COMMISSION, PECO ENERGY COMPANY,
:
: : : : : :
ALBRECHT,
Cross-Appellants v. PENNSYLVANIA PUBLIC UTILITY COMMISSION, PECO ENERGY COMPANY,
:
: : : : : : :

BRIEF OF CHILDREN’S HEALTH DEFENSE, AND BUILDING BIOLOGY INSTITUTE, ET AL AS AMICI CURIAE IN SUPPORT OF APPELLEES/CROSS-APPELLANTS “CUSTOMERS”

Brief of Amicus Curiae Supporting the Appellees/Cross-Appellant “Customers” in
the Appeals from the Commonwealth Court’s October 8, 2020 Order at Docket
Nos. 492 C.D. 2019, 606 C.D. 2019, and 607 C.D. 2019, which affirmed in part,
reversed and remanded in part, and vacated and remanded in part the
Pennsylvania Public Utility Commission’s Opinion and Orders entered at Docket
Nos. C-2015-2475023, C-2015-2475726, and C-2016-2537666

Andrea L. Shaw (ID 89333) Law Office of Andrew H. Shaw, P.C.

-243-7135
-243-7872

Children’s Health Defense 48 Dewitt Mills Road 1227 North Peachtree Pkwy, Suite 202
Peachtree City, GA 30269
NY Bar No. 1999994
[e-mail]
TEL: [phone]
W. Scott McCollough* McCollough Law Firm, P.C. 2290 Gatlin Creek Rd. Dripping Springs, TX 78620 Texas Bar No. 13434100
[e-mail]
TEL: [phone]
FAX: [phone]
*Pro hac vice motion pending
i

TABLE OF CONTENTS
Page
TABLE OF CONTENTS ............................................................................................ i
TABLE OF AUTHORITIES ................................................................................... iii
I. IDENTIFICATION AND STATEMENT OF INTEREST OF AMICI
CURIAE...................................................................................................................... 1
II. STATEMENT OF SCOPE AND STANDARD OF REVIEW ......................... 4
III. STATEMENT OF QUESTIONS PRESENTED ............................................... 8
IV. SUMMARY OF ARGUMENT ......................................................................... 8
V. ARGUMENT ...................................................................................................10
A. Guidelines Remand Decision ......................................................................10
B. Medical, Scientific and Engineering/Technical Information ......................11
C. FCC Admits Adverse Effects ......................................................................18
D. Pulsed RF Affects at Least Some People ....................................................19
E. The Federal Government Recognizes Electro-Sensitivity; Federal and State Law Requires Effective Accommodation ............................................20
1. CDC, U.S. Justice Department and Other Agencies Recognize
Electro-sensitivity Can Lead to Major Life Impairments Requiring
Accommodation ...............................................................................................21
2. ADA, FHA, Rehabilitation Act and PHRA Require
Accommodations to Disabled/Handicapped Individuals Who Would be Negatively Affected by a Smart Meter ............................................................23
3. The PUC is Bound by ADA Title II, the FHA and PHRA; PECO is Bound by the FHA and the Rehabilitation Act ................................................25
F. The PUC’s “Burden of Proof” is Inconsistent with the Disability laws 28
1. PUC Applied Wrong Standard .................................................................28
2. Burden of Proof Inconsistent With Disabilities Laws .............................29
VI. Only Reasonable and Effective Accommodation is Analog Meter ...............31
A. Placement in Yard is Not Reasonable Accommodation .............................32
B. Placement in Yard Does Not Eliminate Harmful RF “Noise” in
House....................................................................................................................32
ii

VII. CONCLUSION ..............................................................................................33
APPENDIX ..............................................................................................................36
LIST OF ADDITIONAL AMICI CURIAE ..........................................................36
CERTIFICATE OF COMPLIANCE .......................................................................59
CERTIFICATION OF CONFIDENTIAL INFORMATION ..................................60
CERTIFICATE OF SERVICE ................................................................................61
ADDENDUM .......................................................................................................... 62
Physicians Statement …………………………………………….. ................... 64
Scientists Statement ……………………………………………. .................... 136
Engineer Report ………………………………………………… ................... 168
Building Biologist Institute Report ……………………………. .................... 184

iii

TABLE OF AUTHORITIES
Federal Cases
Astralis Condo. Ass’n v. Sec’y, U.S. Dep’t of Housing & Urban Dev., 620 F.3d 62 (1st Cir. 2010) ......................................................................................... 29
Calero-Cerezo v. U.S. DOJ, 355 F.3d 6 (1st Cir. 2004) .......................................... 29
Crissman v. Dover Downs Entm’t Inc., 289 F.3d 231 (3d Cir. 2002) ..................... 24
Dodge v. Comptroller of the Currency, 744 F.3d 148 (D.C. Cir. 2014) ................... 8
Envtl. Health Tr., et al v. FCC, Nos. 20-1025, 20-1138, 2021 U.S. App.
LEXIS 24138 (D.C. Cir. Aug. 13, 2021) ............................................................... 2
Friedman v. Cent. Me. Power Co., No. 2:20-cv-00237-JDL, 2021 U.S. Dist.
LEXIS 62585 (D. Me. Mar. 31, 2021) ..................................................... 29, 31, 32 Jackson v. Metro. Edison Co., 419 U.S. 345 (1974) ............................................... 24 Kisor v. Wilkie, 139 S.Ct. 2400 (2019) ...................................................................... 7 Rendell-Baker v. Kohn, 457 U.S. 830 (1982) .......................................................... 24
Theriault v. Flynn, 162 F.3d 46 (1st Cir. 1998) ....................................................... 29
Federal Statutes
29 U.S.C. §794 ......................................................................................................... 25
42 U.S.C. §§3613 ..................................................................................................... 27
42 U.S.C. §12101 ..................................................................................................... 24
42 U.S.C. §12102 ..................................................................................................... 24
42 U.S.C. §12112 ..................................................................................................... 29
42 U.S.C. §3601 ....................................................................................................... 24 42 U.S.C. §3631 ....................................................................................................... 27
Federal Administrative Rules
24 C.F.R. §100.400 .................................................................................................. 25 28 C.F.R. §35.108 .................................................................................................... 29 28 C.F.R. §35.130 .................................................................................................... 24
28 C.F.R. §36.101 .................................................................................................... 29
28 C.F.R. §36.105 .................................................................................................... 24
28 CFR Appendix A to Part 36 - Guidance on Revisions to ADA Regulation
on Nondiscrimination on the Basis of Disability by Public Accommodations and Commercial Facilities ...................................................... 30 Architectural Transportation Barriers Compliance Board, Final Rule, Americans With Disabilities Act (ADA) Accessibility Guidelines for Buildings and Facilities; Recreation Facilities, 67 Fed. Reg. 56352, 56353 (Sept. 3, 2002) ...................................................................................................... 21
iv

Part 36, Appendix C - Guidance to Revisions to ADA Title II and Title III Regulations Revising the Meaning and Interpretation of the Definition of “Disability” and Other Provisions in Order to Incorporate the Requirements of the ADA Amendments Act ...................................................... 30
State Cases
Clay v. Advanced Comput. Applications, 522 Pa. 86, 559 A.2d 917 (1989) ........... 26
Crown Castle NG E. LLC v. Pa. PUC, 234 A.3d 665 (Pa. 2020) ............................. 4
Lazer Spot, Inc. v. Pa. Human Rels. Comm’n, 184 A.3d 200 (Pa. Commw.
Ct. 2018) ............................................................................................................... 29
Phila. Elec. Co. v. Human Rels. Comm’n, 5 Pa. Commw. 329, 290 A.2d 699
(1972 .................................................................................................................... 26 Popowsky v. Pa. PUC, 910 A.2d 38 (Pa. 2006) ........................................................ 7 Povacz v. Pa. PUC, 241 A.3d 481, 491 & n13 (Pa. Commw. Ct. 2020) ................ 10
Federal Agency Decisions
Proposed Changes in the Commission’s Rule Regarding Human Exposure to
Radiofrequency Electromagnetic Fields, 34 FCC Rcd 11687 (2019) ........... 18, 19
State Statutes
1 Pa.C.S. §1921 .......................................................................................................... 9
1 Pa.C.S. §1922 ........................................................................................................ 10
43 Pa. Stat. Ann. §951.............................................................................................. 24
State Administrative Rules
16 Pa.Code §45.9 ..................................................................................................... 25 52 Pa. Code Chapter 57, Subchapter O ..................................................................... 7 6 Pa.Code §44.4 ....................................................................................................... 24
State Administrative Decisions
Catherine J. Frompovich v. PECO Energy Company, Docket No. C-2015-2474602, 2018 Pa. PUC LEXIS 160 (Pa. P.U.C. May 3, 2018) ........................... 6
Catherine J. Frompovich v. PECO Energy Company, Docket No. C-2015-
2474602, Initial Decision (May 11, 2017),
https://www.puc.pa.gov/pcdocs/1522025.pdf ....................................................... 6
Edward Lucey v. Metropolitan Edison Company, Docket No. C-2018-3003679, 2020 PA. PUC LEXIS 522 (Pa. P.U.C. October 8, 2020) ................... 26
v

Letter of Notification of Philadelphia Electric Company Relative to the Reconstructing and Rebuilding of the Existing 138 kV Line to Operate as the Woodbourne-Heaton 230 kV Line in Montgomery and Bucks Counties 1992 Pa. PUC LEXIS 160 (Pa. P.U.C., No. A-110550F0055, filed Mar. 26, 1993) .............................................................................................................. 28
Negley v. Metropolitan Edison Company, Docket No. C-2010-2205305,
2010 Pa. PUC LEXIS 1919 (Pa. P.U.C. December 15, 2010) .............................. 5
Other Authorities
154 Cong. Rec. S8842 (daily ed. Sept. 16, 2008) (Statement of the
Managers) ............................................................................................................. 29
FCC OET Bulletin 56 .............................................................................................. 13 International Classification of Diseases, 10th Revision, Clinical Modification (ICD-10-CM), https://icd10cmtool.cdc.gov/ ................................. 21 National Institute of Building Sciences (NIBS), Indoor Environmental Quality (IEQ) Final Report (July 14, 2005) ......................................................... 22 The U.S. Department of Justice Civil Rights Division - Americans with Disabilities Act Title II Technical Assistance Manual Covering State and
Local Government Programs and Services .......................................................... 27

1

I. IDENTIFICATION AND STATEMENT OF INTEREST OF AMICI CURIAE1
Children’s Health Defense (“CHD”) is a national non-profit 501(c)(3)
organization. CHD has no parent corporation. No publicly-held company has a
10% or greater ownership interest.
CHD’s mission is to end the epidemic of children’s chronic health
conditions by working aggressively to eliminate harmful exposures to
environmental toxins via education, to obtain justice for those already injured and
to promote protective safeguards. The emissions from pulsed radio-frequency (RF)
based wireless technologies including from Wi-Fi, cell towers and smart meters are
a major contributory factor in the growing epidemic of sickness among adults and
children. Many CHD members and their children are sick from wireless
technology and are adversely affected by smart meters. For some, the exposure
aggravates other conditions. We are approached daily by adults and children who
have become sick and ask for our help.
In May 2020, 6,231 people who declared that they and/or their children are
sick from wireless joined a CHD submission to the FCC. 182 of them were from

1 No person or entity other than the named amici, their members or counsel has (i)
paid in whole or in part for the preparation of this brief; or (ii) authored in whole or
in part this brief.
2

Pennsylvania.2 The decision in this case will directly affect CHD and its
Pennsylvania members. The court’s decision will also affect nationwide policy and
therefore, our members throughout the country.
We also have taken legal action to protect the injured. Most recently, on
August 13, 2021, the United States Court of Appeals for the District of Columbia
Circuit ruled for CHD and other petitioners in a case challenging the FCC’s 2019
decision affirming the adequacy of its RF guidelines for public health purposes.
Envtl. Health Tr., et al v. FCC, Nos. 20-1025, 20-1138, 2021 U.S. App. LEXIS
24138 (D.C. Cir. Aug. 13, 2021) (Guidelines Remand). The court held that the
FCC decision denying non-cancer harm was arbitrary, capricious and not evidence
based. This decision is highly relevant to the issues before the Court. See Part V.A.
Building Biology Institute
The Building Biology Institute (“BBI”) is a 501(c)(3) non-profit corporation
now in its twenty-eighth operating year. BBI does not have a parent corporation.
No publicly-held company has a 10% or greater ownership interest.
BBI’s mission is to help meet the public demand for proven methods that
secure homes, schools and workplaces from toxins including RF radiation (RFR).
BBI’s experts work with doctors and patients to remediate exposures in patients’
homes. They are on the ground, seeing widespread sickness from RFR exposure.

2 https://www.fcc.gov/ecfs/filing/105191672708448.
3

They have witnessed the effects of smart meters and the tremendous health
improvements after these meters are removed. BBI’s experts are critical in
addressing electro-sensitivity and RF related injuries.3
Seventy-nine (79) other health and environmental organizations promoting
safe-tech, join in this Amicus. They are further described in the Appendix.
All Amici have local, national and global experience and expertise relating to
the underlying and broader legal, technical, scientific, medical issues before the
Court. Even more important, Amici see – every day – the enormous difficulty faced
by individuals who, for whatever reason, simply cannot tolerate the radiation
emitted from pulsed radio-frequency based wireless technologies including smart
meters.

3https://www.womenscollegehospital.ca/assets/pdf/environmental/Preliminary%20
Clinical%20Guidelines%20%20for%20EHS.pdf#page=8.
4

II. STATEMENT OF SCOPE AND STANDARD OF REVIEW
Amici adopt the “Customers” Statement of Scope and Standard of Review,
but provide this supplement:
“While this Court has never expressly adopted the federal Chevron
approach, we have recognized that ‘[t]he Chevron approach to such cases at the
federal level, however, is indistinguishable from our own approach to agency
interpretations of Commonwealth statutes.’” Crown Castle NG E. LLC v. Pa. PUC,
234 A.3d 665, 679 n.11 (Pa. 2020). Chevron and this Court’s jurisprudence both
require that the PUC’s interpretation be granted little to no deference, for several
reasons.
The first reason is simple: the statute is unambiguous4 and therefore no
deference is due. Crown Castle, 234 A.3d at 677-78 (Pa. 2020). The
Commonwealth Court correctly held (p.13) that “nothing in the language of Act
129 facially requires every customer to endure involuntary exposure to RF
emissions from a smart meter.”
Section 807(f)(2) could not be clearer:
(f) Smart meter technology and time of use rates. …. (2) Electric distribution companies shall furnish smart meter technology as follows:

4 PUC Br. pp. 8, 16-19 and Energy Association Amicus at pp. 13-15 so contend.
5

(i) Upon request from a customer that agrees to pay the cost of the smart meter at the time of the request.5 (ii) In new building construction. (iii) In accordance with a depreciation schedule not to exceed 15 years.” [emphasis added].
Smart Meter Implementation Order Para B.4 contains the PUC’s entire
analysis: “The Commission believes that it was the intent of the General Assembly
to require all covered EDCs to deploy smart meters system-wide when it included
a requirement for smart meter deployment ‘in accordance with a depreciation
schedule not to exceed 15 years.’” See also, Negley v. Metropolitan Edison
Company, Docket No. C-2010-2205305 pg. 4-5, 2010 Pa. PUC LEXIS 1919, *6
(Pa. P.U.C. December 15, 2010). The PUC therefore contends that the legislature
intended to mandate ubiquitous, non-optional deployment when it required a 15-
year depreciation schedule in Section 807(f)(2)(iii).
The conclusion does not follow. The statute’s provision requiring a 15-year
depreciation schedule says (and implies) nothing about mandatory placement. It
just means that whatever capital investment is required to obtain enough meters to
satisfy customer demand must be depreciated over 15 years. Utilities routinely

5 The legislative history confirms that the legislation was not intended to require placement. House Bill 2200 as passed would have obtained that result. But the Senate deleted the relevant House language and substituted the current language.
The House then concurred. The authors of the Senate changes stated that one of
their specific intentions was to allow customers to choose whether to obtain a
smart meter and make placement not mandatory. See Sen. Journal, Oct. 8, 2008 at
2626-27 (Remarks of Senators Tomlinson and Boscola).
6

make capital investments for utility plant that does not directly affect every
ratepayer. All such investments are recovered through depreciation expense until
fully recovered. Depreciation concerns how overall rates are set and has nothing to
do with the utility’s customer rules. See, e.g., Pa. Power & Light Co. v. Pa. Pub.
Util. Com., 10 Pa. Commw. 328, 311 A.2d 151 (1973). The reliance on that part of
Act 129 was misplaced.
The PUC’s brief interpretive analysis in the Smart Meter Implementation
Order did not address the far more relevant and truly unambiguous language in
807(f)(2)(i). This provision clearly contemplates an individual customer request
and commitment to pay the cost. The PUC has admitted that “[a] plain reading of
the statute may suggest that there is an ‘opt-in’ or ‘opt out’ available.” Catherine J.
Frompovich v. PECO Energy Company, Docket No. C-2015-2474602, Initial
Decision p. 24 (May 11, 2017), https://www.puc.pa.gov/pcdocs/1522025.pdf,
adopted, Catherine J. Frompovich v. PECO Energy Company, Docket No. C-
2015-2474602, 2018 Pa. PUC LEXIS 160 (Pa. P.U.C. May 3, 2018), but it insists
on not following the plain reading in favor of a strained interpretation of a different
subsection that has nothing to do with the question.
Second, the Commission’s interpretation of Act 129 has admittedly been
officially held and consistent, but it did not arise from rulemaking procedures. The
Commission first reached its conclusion that Act 129 contemplates mandatory
7

deployment with no opt-out in Smart Meter Procurement and Installation, Docket
No. M-2009-2092655, 2009 Pa. PUC LEXIS 265, 274 P.U.R.4th 238 (Order
entered June 24, 2009) (Smart Meter Implementation Order). That proceeding did
not employ formal rulemaking processes or conclude with a legislative rule or
regulation.6 The PUC’s reading is an interpretive rule. Crown Castle, 234 A.3d at
667-678.7 The Commission’s reading of Act 129 is at best entitled to Skidmore-
type deference (muddled as that federal doctrine may be) and resolution requires
recourse to basic statutory construction tools. Crown Castle, 234 A.3d at 694
(Wecht, J. Concurring), citing Kisor v. Wilkie, 139 S.Ct. 2400, 2415-2416 (2019).
Third, agencies do not receive Chevron-type deference when an agency
claims its organic statute overrides other statutory provisions entirely outside the
statute the Commission is charged with administering, especially when, as is the
case with the ADA, FHA and PHRA, they are administered by several agencies.
The court “must decide for [itself] the best reading.” Dodge v. Comptroller of the
Currency, 744 F.3d 148, 155 (D.C. Cir. 2014).
6 This distinguishes Popowsky v. Pa. PUC, 910 A.2d 38 (Pa. 2006), which involved a legislative rule.
7 The only extant legislative rules or regulations on the topic of Advanced
Metering Deployment clearly contemplate voluntary customer participation and
customer-driven selection of the particular meter to be used. See 52 Pa. Code
Chapter 57, Subchapter O. These legislative rules predate Act 129, but have not
been repealed or amended.
8

III. STATEMENT OF QUESTIONS PRESENTED
Amici adopt the Statements of Questions Presented set forth in the
“Customers’” Briefs.
IV. SUMMARY OF ARGUMENT
1. Smart meter deployment has been allowed and considered safe
because the meters comply with the Federal Communications Commission
(“FCC”) radiofrequencies exposure guidelines. As a result of the Guidelines
Remand ruling, the FCC guidelines can no longer be relied on for an assurance of
safety as to non-cancer harm and harm to the environment. Further, the FCC has
now admitted to an adverse neurological response and symptoms similar to those
suffered by people with electro-sensitivity.
2. Knowledge has significantly advanced in the five years since 2016
when the administrative record below was created. It is now quite clear exposure
can lead to negative health effects. Those who suffer an RF-related impairment
must be afforded reasonable accommodation.
3. The PUC’s interpretation is wrong. First, the statute cannot be read
to contain a universal mandate; it clearly envisions customer consent. Second,
regardless of the legislature’s word choice the state cannot lawfully force a
customer to accept a smart or digital meter when mandatory installation results in
disability discrimination, exacerbates existing impairments or forces people to
9

abandon their home. There must be effective accommodation. Third, neither the
Commission nor the utility can or should second-guess an attending physician’s
finding of impairment and the need for RFR avoidance. That too is prohibited by
disability laws.
4. The impaired cannot be required to endure an interminable and
expensive proceedings that requires them to meet an irrelevant and almost
impossible evidentiary burden when the accommodation itself costs less than
$100. Disability laws flatly prohibit imposing this burden. The rule is simple:
accommodation in the form of an analog meter is required if a customer presents
a professional assessment of impairment and a need for RF avoidance.
5. The Court can dispose of this case without directly wading into
health effects. All that is required is a holding that Act 129 does not mandate
smart meter placement absent customer consent. This outcome results from both
the unambiguous terms in the legislation and proper application of statutory
interpretation, including but not limited to “the consequences of a particular
interpretation.” 1 Pa.C.S. §1921(6).
6. If it does reach the health issues, the Court should ensure that those
with electro-sensitivity receive accommodation in the form of an analog meter.
Any reading that requires an impaired customer to accept a smart or digital meter
will conflict with other state and federal laws. 1 Pa.C.S. §1922(3) states that
10

legislation should not be interpreted in a way that renders the provision
unconstitutional. Thus, Act 129 cannot be interpreted to obtain a result that
would conflict with the rights, remedies and venue provisions in other state or
federal disability laws. These other laws require reasonable accommodation in
the form of an analog meter.
V. ARGUMENT
A. Guidelines Remand Decision
The Guidelines Remand is highly relevant to this case. The PUC decisions
below extensively relied on the FCC’s guidelines as part the “safety” findings.
Murphy Order, p. 68 and 84-85, R.197a and 213a-14a. The utility did so as well.
PECO Br. 1, 4, 6, 26-28, 34.8
As the Guidelines Remand court noted, the FCC’s emissions limits do not
satisfactorily consider electro-sensitivity9 or the effects of pulsation and
modulation10 used by wireless technologies (like smart meters).11 The FCC

8 The Commonwealth Court disclaimed any such reliance, Povacz v. Pa. PUC, 241 A.3d 481, 491 & n13 (Pa. Commw. Ct. 2020), but the PUC and utilities’ briefs each rely on the FCC guidelines.
9 2021 U.S.App.LEXIS 24134 at *10-*14.
10 2021 U.S.App.LEXIS 24134 at *29-*30.
11 https://childrenshealthdefense.org/wp-content/uploads/Corrected-Brief-and-
Hyperlinks-Table-Postable-pdf-A1.pdf#page=58.
11

guidelines cannot be a basis for any conclusions regarding RF safety including for
smart meters, yet that is a primary foundation for the PUC’s conclusions below.
The case exposed that no proper review was conducted by any of the
responsible federal agencies regarding non-cancer harm from exposure to radiation
levels below the FCC’s guidelines.12 The petitioners in that case filed 11,000 pages
of evidence of non-thermal harm including of electro-sensitivity; neurological
effects; humans’ biological response to pulsation and modulation; and effects of
smart meters.13 The court ruled the FCC erroneously dismissed this extensive
evidence without adequate explanation14 and remanded the decision to the FCC to
conduct a review and provide reasoned explanations.15
B. Medical, Scientific and Engineering/Technical Information
To support their arguments, Amici are providing:
(1) A Statement by 57 physicians who combined have over 3,000
patients suffering from electro-sensitivity like the “customers,” or other
conditions aggravated by RF exposure. The physicians explain recent

12 2021 U.S.App.LEXIS 24134 at *14-*20.
13 https://childrenshealthdefense.org/wp-content/uploads/Corrected-Brief-and-
Hyperlinks-Table-Postable-pdf-A1.pdf.
14 2021 U.S.App.LEXIS 24134 at *13-*14, *24-30.
15 2021 U.S.App.LEXIS 24134 at *43-*45.
12

medical developments, diagnosis guidelines and the effects of smart meters
on their patients.16
(2) A Statement by scientists with expert knowledge of pulsed RFR
effects. Combined they published hundreds of studies on RF/EMF effects
and reviewed thousands. They explain recent developments and the
scientific evidence as it applies to smart meters. They emphasize that smart
meters generated pulsed RF is a significant harm agent.17
(3) An expert engineer Report addressing smart meters’ operation.
This report explains how smart meters generate constant RF pulses that are
also conducted through electrical wiring, thereby creating a whole-home
antenna.18
(4) A Report by the Building Biology Institute’s President. BBI’s
experts work with the injured to mitigate their homes from RF exposure.
They see the torture smart meters cause to those who are affected and the
health transformations after the smart meter is removed. The Report also
explains why it is impossible to sufficiently mitigate homes with smart or

16 Addendum Physicians Statement¶¶17-42.
17 Addendum Scientists Statement, ¶¶13-25.
18 Addendum Engineer Report, ¶¶9-17.
13

digital meters and concludes that the only reasonable accommodation is a
$100 analog meter.19
The Engineering and Science experts explain how pulsation injects RF
“bursts” or turns the signal on/off.20 The FCC emissions guidelines protect only
from emissions that are so high they create a heating or “thermal effect.”21 They do
not protect or recognize biological responses to non-thermal pulsed and modulated
RF emissions.22 The problem is that the factual premise – the non-existence of
non-thermal biological and adverse effects – underlying the current RF guidelines
is outdated and demonstrably false. This was one of the major drivers behind the
Guidelines Remand decision. 2021 U.S.App.Lexis 24138 *10-*12, *30.
Despite the claims by the utilities and the PUC, there is no doubt the human
body responds to pulsed RF radiation, even at non-thermal levels. The FCC has
now agreed. Doctors routinely use pulsed RF/EMF for medical treatment because
they generate biological responses.23 With chronic exposure these biological
19 Addendum BBI Report at ¶¶27-34.
20 The utility’s witnesses assert the meters do not employ pulsation, but they do so by mischaracterizing what a “pulse” is. It is uncontested that the meters are not in constant communications mode, so they obviously turn on and off. That is “pulsation.”
21 FCC OET Bulletin 56, at 6-7 (August 1999), available at
https://tinyurl.com/y5mbsymn.
22 See Scientists’ Statement for expiation of RF basics ¶¶1-4.
23 Scientists Statement ¶43.
14

responses can lead to significant health problems.24 The mechanisms of harm from
RF exposure that transforms these biological effects into adverse effects are also
known and include oxidative stress.25, 26 These adverse effects can rise to the level
of functional impairment. For some they are life-threatening.27
Since 2016, the scientific and medical consensus regarding non-thermal
harms has become even more conclusive.28 In January 2021 the Swiss
government’s expert advisory committee on EMF and non-ionizing radiation,
BERENIS,29 concluded an evaluation of the scientific literature on non-thermal
RF/EMF.30 The committee’s paper concludes that exposure could cause or worsens
several chronic illnesses and acknowledged oxidative stress as the underlying
causal harm mechanism.

24 Scientists Statement ¶¶7-11.
25 https://childrenshealthdefense.org/wp-content/uploads/rf-2018-golomb-
diplomats-3.pdf.
26 https://childrenshealthdefense.org/wp-content/uploads/rf-2015-yakymenko-oxidative-stress.pdf; https://bioinitiative.org/wp-content/uploads/2020/09/3-RFR-Free-Radical-Oxidative-Damage-Abstracts-2020.pdf.
27 Physicians Statement ¶¶14, 26, 40.
28 Scientists Statement ¶¶13-31; Physicians Statement ¶¶16-20, 27-32.
29 https://www.bafu.admin.ch/bafu/en/home/topics/electrosmog/newsletter-of-the-
swiss-expert-group-on-electromagnetic-fields-a/beratende-expertengruppe-nis-
berenis.html.
30https://childrenshealthdefense.org/wp-content/uploads/rf-swiss-berenis-2021-
report.pdf.
15

In 2020, New-Hampshire’s legislative-appointed committee investigated 5G
and wireless harms and published findings. It concluded that non-thermal harms
are established, acknowledged electro-sensitivity and stressed the need for
accommodations.31
Electro-sensitivity is a condition whereby the patients manifest a
constellation of mainly neurological symptoms after RFR exposure. The scientific
literature recites a host of symptoms, including headaches, memory and cognitive
problems, sleep problems, heart palpitations and/or increased heart rate, ringing in
the ears, exhaustion, skin rashes, tingling, nose bleeds, dizziness, and burning
sensations.32 RF exposure has been directly connected to these symptoms in
hundreds of studies.33 Official diagnosis guidelines have existed since 2011.34

31 New Hampshire is the only US state that has conducted an independent investigation as to the harms of these technologies.
32 Note the overlap with the FCC’s 2019 list of symptoms in FCC RF/EMF
Proposed Changes, 34 FCC Rcd at 11744, ¶122, n.328. Part V.C.
33 https://childrenshealthdefense.org/wp-content/uploads/rf-2018-golomb-
diplomats-3.pdf; https://childrenshealthdefense.org/wp-content/uploads/rf-2018-
neurological-lai-book-chapter.pdf; https://childrenshealthdefense.org/wp-
content/uploads/rf-2014-electrosensitivity-dr-blythe.pdf.
34 https://childrenshealthdefense.org/wp-content/uploads/rf-2011-austrian-medical-
association-guidelines.pdf.
16

They were updated in 2016,35 to include biomarkers36 and genetic predispositions37
found by studies on many hundreds of electro-sensitive patients. Additional
biomarkers were identified in 2020.38
These studies establish that electro-sensitivity is not a sensitivity, nor is it
“idiopathic.” It involves severe physiological injuries directly associated with
pulsed RF exposure, including blood-brain barrier leakage; damage to the immune
system; chronic inflammation; impaired melatonin production and impaired blood
flow to the brain.39 A 2017 fMRI study shows clear evidence of impaired blood
flow in 10 electro-sensitive subjects.40
Electro-sensitivity is a “spectrum condition.” Some experience discomfort
while others are entirely debilitated. Those affected become progressively

35 https://childrenshealthdefense.org/wp-content/uploads/rf-2016-europaem-
guidelines.pdf.
36 https://pubmed.ncbi.nlm.nih.gov/26613326/.
37 https://pubmed.ncbi.nlm.nih.gov/24812443/.
38 https://childrenshealthdefense.org/wp-content/uploads/rf-2020-Belpomme-guidelines.pdf.
39https://www.womenscollegehospital.ca/assets/pdf/environmental/Preliminary%2
0Clinical%20Guidelines%20%20for%20EHS.pdf;
https://childrenshealthdefense.org/wp-content/uploads/rf-2018-golomb-diplomats-
3.pdf; https://childrenshealthdefense.org/wp-content/uploads/rf-2020-Belpomme-
guidelines.pdf.
40 https://pubmed.ncbi.nlm.nih.gov/28678737/.
17

intolerant to radiation levels they could previously tolerate. Exposure avoidance is
the only effective treatment.41
In December 2020, the National Academy of Sciences, Engineering and
Medicine (NAS) concluded that the diplomats’ “mystery illness” is likely caused
by pulsed RF.42 Prof. Beatrice Golomb MD PhD,43 2018 paper44 was the first to
analyze the science in detail and to show that pulsed RF is the likely cause of the
symptoms suffered by some US diplomats in Cuba and China.45 She concluded
that the diplomats essentially suffer from electro-sensitivity (which she refers to as
“Microwave Illness”).46 Her analysis included case studies on people sickened by
smart meters.47 She gave a detailed scientific analysis to each of the diplomats’ and

41 Physicians Statement ¶¶7, 38; https://childrenshealthdefense.org/wp-content/uploads/rf-2016-europaem-guidelines.pdf#page=24; https://childrenshealthdefense.org/wp-content/uploads/rf-2020-Belpomme-
guidelines.pdf#page=14; https://childrenshealthdefense.org/wp-content/uploads/rf-
2018-golomb-diplomats-3.pdf#page=21; https://childrenshealthdefense.org/wp-
content/uploads/rf-2014-electrosensitivity-dr-blythe.pdf#page=5.
42 https://www.nap.edu/read/25889/chapter/1.
43 Prof. Golomb signed the Scientists Statement.
44 https://childrenshealthdefense.org/wp-content/uploads/rf-2018-golomb-diplomats-3.pdf.
45 https://pubmed.ncbi.nlm.nih.gov/30183509/.
46 This Brief uses “Electro-sensitivity” but the syndrome is also called “Electromagnetic Hyper-Sensitivity” (“EHS”), “Microwave Sickness,” and
“Radiation Sickness.” PECO calls it “Idiopathic Environmental Intolerance.”
47 Prof. Golomb signed the Scientists Statement.
47 https://childrenshealthdefense.org/wp-content/uploads/rf-2018-golomb-
diplomats-3.pdf pages: 15, 18-22, 25, 37, 38.
18

electro-sensitivity symptoms and showed how they can result from RF exposure.
She was invited to present to the NAS committee.48
Smart meters can be the original cause or a subsequent aggravating cause.
They are, however, undoubtedly harmful to anyone with electro-sensitivity.49 As
the guidelines for diagnosis and the physicians’ statement emphasize, the only
mitigation and treatment for those affected by RF is rigid, constant RF exposure
avoidance, in every aspect of their lives. This is particularly so when it comes to
peoples’ last refuge: their home. For all these reasons any regime that forces
people to choose between a mandatory smart meter or not having electric (or
water, or gas) utility service, is especially pernicious.50
C. FCC Admits Adverse Effects
The FCC admitted in 2019 that at least some RFs can cause non-thermal
adverse effects with RF frequencies ranging between 3 KHz and 10 MHz.51 Pulsed

48 https://childrenshealthdefense.org/rf-nas-agenda-golomb/;
https://childrenshealthdefense.org/wp-content/uploads/rf-nas-golumb-email.pdf.
49 This is part of the problem with the PUC’s burden of proof requirements. The issue is not what caused the impairment; it is whether the smart or digital meter interferes in any manner with a person’s ability to engage in major life activities. See Part V.F.
50 Some people with electro-sensitivity also have other health issues and use medical treatment devices that require electricity.
51 Proposed Changes in the Commission’s Rule Regarding Human Exposure to
Radiofrequency Electromagnetic Fields, 34 FCC Rcd 11687, 11743-11745, ¶¶122-
124 & nn. 322-335 (2019). It also noted that these harms occur instantaneously.
The FCC currently averages exposure levels over 30 minutes, which completely
19

RF created by the AC/DC conversion performed by smart and digital meters’
Switch Mode Power Supply (SMPS), generates frequencies between 2-50 KHz,
which fall squarely in the range identified by the FCC as problematic.52 The FCC
noted that “[a]dverse neural stimulation effects…include acute effects such as
perception of tingling, shock, pain, or altered behavior due to excitation of tissue in
the body’s peripheral nervous system.” 34 FCC Rcd at 11743-11744, ¶122 n.328.
These are the same symptoms suffered by the “customers” and by others who
report adverse health effects from smart meters. 34 FCC Rcd at 11742-11744,
¶¶119-122.
D. Pulsed RF Affects at Least Some People
The FCC guidelines can no longer be said to provide any assurance
regarding the public’s health for non-cancer harms. The FCC has expressly
acknowledged that RF emissions such as those from smart and digital meters can
cause the very same symptoms reported by the Customer Petitioners and those who
have developed electro-sensitivity or suffer from other conditions that are
aggravated by RFR exposure. Those affected have a right to accommodation,
regardless of what is “deemed safe” for the general population.

obscures pulsation effects. It has admitted instantaneous effects for the RF
frequency band involved in smart meter wire conduction.
52 Engineer Report ¶¶14-17.
20

To analogize, the U.S. Agriculture Department and Food and Drug
Administration each regulate peanut and peanut product quality. They ensure
peanuts and peanut products are safe for most people. Additional protective steps
are taken, to ensure those with nut allergies are not inadvertently (or purposefully)
exposed to “deemed safe” nuts.53 Similarly, measures must be taken to allow those
adversely affected by RF to avoid exposure from even general population “deemed
safe” emissions.
A state electric utility regulator certainly should not issue a mandate that
someone with an impairment made worse by pulsed RFR must have a smart or
digital meter as a condition of utility service unless they fund a costly lawsuit and
satisfy a burden of proof that is inappropriate and almost impossible to meet given
the nature of the condition. The regulator cannot base lawful findings on utility-
funded “expert” doctors that never examined the customer.
E. The Federal Government Recognizes Electro-Sensitivity; Federal and State Law Requires Effective Accommodation
As noted above, the FCC has now agreed that RF can evoke a non-thermal
adverse neural response to at least some RF emissions. The CDC has diagnosis and
injury codes for exposure related injuries. Various federal agencies recognized the

53 See, e.g., U.S. Dept. of Justice, Civil Rights Division, Questions and Answers
About the Lesley University Agreement and Potential Implications for Individuals
with Food Allergies, available at https://www.ada.gov/q&a_lesley_university.htm.
21

condition. Three federal laws and a state law directly require accommodations. The
federal government has outlined the proof required for those who seek
accommodation.
1. CDC, U.S. Justice Department and Other Agencies Recognize Electro-sensitivity Can Lead to Major Life
Impairments Requiring Accommodation
The federal government recognizes RF/EMF radiation exposure related
sickness. The Centers for Disease Control’s 2022 Classification of Diseases Codes
Clinical Modification and Procedural Classification System implements the
International Classification of Diseases, 10th Revision, Clinical Modification
(ICD-10-CM) .54 The “diagnosis code” for Radiation Sickness” is “T66.” The
“injury” code for “Exposure to Other Nonionizing Radiation” is “W90.” These
codes cover Electro-sensitivity along with other RF exposure-related injuries and
maladies.
The “Access Board,” the federal agency responsible for publishing
Accessibility Guidelines used by the Justice Department to enforce the ADA, has
held that “electromagnetic sensitivities may be considered disabilities under the
ADA.”55 The Access Board contracted with the National Institute of Building

54 Available at https://icd10cmtool.cdc.gov/.
55 Architectural Transportation Barriers Compliance Board, Final Rule, Americans
With Disabilities Act (ADA) Accessibility Guidelines for Buildings and Facilities;
Recreation Facilities, 67 Fed. Reg. 56352, 56353 (Sept. 3, 2002) (“The Board
recognizes that multiple chemical sensitivities and electromagnetic sensitivities
22

Sciences (NIBS) 2005 to recommend accommodations. NIBS concluded that RF
could render buildings “inaccessible” to those “who are electromagnetically
sensitive.”56
The US. Department of Labor’s Office of Disability Employment Policy
issued guidelines for accommodations in 2015.57 They state:
…the nature of electromagnetic sensitivity is such that even levels that are deemed safe for the general public can cause trigger symptoms for individuals who are hypersensitive...and therefore may need accommodation. … Individuals with electromagnetic sensitivity may experience … fatigue, weakness, neurological issues, immunological issues,
gastrointestinal issues, increased irritability, lack of ability to think clearly
and quickly, sleep disturbance, overall malaise, and anxiety…Common
workplace issues involve exposure to Wi-Fi, cell phones.
General considerations include: ...Relocate workplace away from areas where symptoms are triggered…limiting certain types of devices in the vicinity of the employee’s workstation... Provide wired telephones and network connections.
The US Department of Education (“DOE”) agrees that people with other
conditions may also develop intolerance to RF/EMF. In a memorandum regarding
may be considered disabilities under the ADA if they so severely impair the neurological, respiratory or other functions of an individual that it substantially limits one or more of the individual’s major life activities.”).
56 National Institute of Building Sciences (NIBS), Indoor Environmental Quality
(IEQ) Final Report (July 14, 2005), © 2005, National Institute of Building
Sciences. A web-based version of the NIBS IEQ Final Report is available at
https://www.access-board.gov/research/building/indoor-environmental-quality/.
57 https://childrenshealthdefense.org/wp-content/uploads/rf-accomodation-
labor.pdfNetwork-EMS.pdf.
23

accommodation of people with Multiple Chemical Sensitivities (“MCS”), they
recommend minimizing exposure to electromagnetic fields and radiation because it
may trigger MCS symptoms. The memo emphasizes the importance of their home
as a refuge and sanctuary free of EMF.
…[I]ndividuals affected by MCS have created “sanctuaries” relatively free
from chemical emissions and electromagnetic fields in their homes. Because
of the serious impact of even an accidental unavoidable exposure, people often spend as much time at home as possible and often cannot participate fully in society. As a result, they may experience intense isolation, loss of self-esteem, and depression from not being able to have an active work, family, or social life.58
2. ADA, FHA, Rehabilitation Act and PHRA Require Accommodations to Disabled/Handicapped Individuals Who Would be Negatively Affected by a Smart Meter
Electricity is the “service” offered by PECO. The meter facilitates billing
and demand response, but it is not the “service.” If PECO’s wireless smart meter
cannot be tolerated due to a medical condition related to a disability or handicap,
forced installation as a condition of utility service will discriminate against the
customer who is “otherwise qualified” but will suffer disconnection and loss of
utility service.

58 https://www2.ed.gov/policy/speced/guid/rsa/im/2002/im-02-04.pdf. A study
published in 2020 on 2,000 people with electro-sensitivity and/or chemical
sensitivity showed that once a person developed one of these conditions, they are
highly likely to develop the other. https://childrenshealthdefense.org/wp-
content/uploads/rf-2020-Belpomme-guidelines.pdf.
24

The Fair Housing Act (“FHA”),59 Americans with Disabilities Act
(“ADA”),60 and the Pennsylvania Human Relations Act (PHRA)61 require
accommodations relating to a “physical or mental impairment” that “substantially
limits one or more of the major life activities.” See, e.g., 42 U.S.C. §12102(1)(A);
28 C.F.R. §36.105; 16 Pa.Code §44.4.
ADA Title II and the PHRA apply insofar as the PUC is establishing binding
practices the utility must implement. 28 C.F.R. §35.130(a), (b)(1), (6), (7).62 State
agency prescribed practices cannot discriminate against the disabled by denying
access to essential electric utility service. Id. The PUC’s regulations must allow for
“reasonable modifications in policies, practices, or procedures when the
modifications are necessary to avoid discrimination on the basis of disability,
unless the public entity can demonstrate that making the modifications would
fundamentally alter the nature of the service, program, or activity.” 28 C.F.R.
§35.130(b)(7).
59 42 U.S.C. §3601, et seq.
60 42 U.S.C. §12101, et seq. ADA Title II prohibits a state-level regulatory requirement that mandates discrimination. USDOJ Title II TAM, supra.
61 43 Pa. Stat. Ann. §951, et seq.
62 Amici are not asserting that the utility has become a state actor and subject to
Title II. C.f. Rendell-Baker v. Kohn, 457 U.S. 830, 842 (1982); Jackson v. Metro.
Edison Co., 419 U.S. 345, 350 (1974); Crissman v. Dover Downs Entm’t Inc., 289
F.3d 231, 243 (3d Cir. 2002). The PUC and the state – the ones allegedly imposing
mandatory smart meters – are the state actors for purposes of ADA Title II.
25

A mandatory smart meter program also fails muster under the FHA. It
“objectively” interferes with the “exercise or enjoyment of rights granted or
protected by” 42 U.S.C. §§3604 or 3605: it makes the occupants sick or sicker, and
therefore violates 42 U.S.C. §3617. See 24 C.F.R. §100.400(b), (c)(1), (2). 42
U.S.C. §3604(f)(1) and 16 Pa.Code §45.9 make it unlawful to “make unavailable
or deny, a dwelling” and that is exactly what a smart meter effectively does to
those who cannot tolerate the radiation emitted from the device. They will be
constructively evicted.
The Rehabilitation Act, 29 U.S.C. §794 prohibits disability discrimination
by any entity receiving federal financial assistance.63 PECO obtained a federal
SmartGrid Investment Grant. PECO Principal Br. p. 18, n.39,64 so it is subject to
the Rehabilitation Act nondiscrimination mandate.
3. The PUC is Bound by ADA Title II, the FHA and PHRA; PECO is Bound by the FHA and the Rehabilitation Act
The PUC has consistently erred by refusing to consider the impact of federal
and state disability/handicap laws. It is true the PUC “lacks jurisdiction to enforce”

63 “No otherwise qualified individual with a disability...shall, solely by reason of
her or his disability, be excluded from the participation in, be denied the benefits
of, or be subjected to discrimination under any program or activity receiving
Federal financial assistance….” 29 U.S.C. § 794(a).
64 Nothing in the grant requires a mandate that all customers accept smart meter
installation.
26

the ADA, FHA, Rehabilitation Act or PHRA as a general matter. See Edward
Lucey v. Metropolitan Edison Company, Docket No. C-2018-3003679, 2020 PA.
PUC LEXIS 522, *15 (Pa. P.U.C. October 8, 2020), citing Catherine J.
Frompovich v. PECO Energy Company, Docket No. C-2015-2474602, 2018 Pa.
PUC LEXIS 160 *69 (Pa. P.U.C. May 3, 2018)(emphasis added).65 But what
everyone involved has missed is that the PUC is bound by ADA Title II and cannot
impose practices or policies in derogation of ADA requirements. Act 129 should
not be read to impose a regulatory mandate that would directly violate the ADA
Title II prohibition on state-level policies and practices that lead to disability
discrimination without reasonable and effective accommodation.

65 These orders state the complainant should go to state or federal court to raise the
disability claim. The problem is that the Pennsylvania Human Relations
Commission is a mandatory prerequisite to any state court action seeking a remedy for disability discrimination. Clay v. Advanced Comput. Applications, 522 Pa. 86, 559 A.2d 917 (1989). On the other hand, Phila. Elec. Co. v. Human Rels. Comm’n, 5 Pa. Commw. 329, 290 A.2d 699 (1972) holds the PHRC could not entertain any such complaint; the petitioner would be sent back to the PUC. The Commission’s interpretation therefore leads to an endless “no state jurisdiction” loop. Statutes
should not be construed to lead to such absurd results. The answer to this seeming
conundrum is simple, however. The Commission needs to merely acknowledge it
cannot impose a practice or policy that violates the disabilities laws and ensure that
the utilities offer reasonable and effective accommodations.
27

The U.S. Department of Justice Civil Rights Division’s Americans with
Disabilities Act Title II Technical Assistance Manual Covering State and Local
Government Programs and Services66 makes this eminently clear:
…a public entity may not establish requirements for the programs or
activities of licensees that would result in discrimination against qualified
individuals with disabilities
If the PUC’s interpretation of Act 129 is upheld on appeal and becomes
final, the Commission (the state) is subject to suit under ADA Title II. Similarly,
under the FHA the state might be subject to damages under 42 U.S.C. §§3613(c),
3631(a), (a)(1), since a state regulatory mandate constitutes “color of law” under
which handicapped individuals may suffer grievous harm. The statute should not
be construed to impose a mandate because it would result in direct conflict with
federal law and expose the state to liability.
The Commission and the Court must consider the impact of the ADA, FHA,
Rehabilitation Act and the PHRA on these issues as part of any interpretative
analysis whether Act 129 can be reasonably interpreted as mandatory. The statute
should not be read to compel a violation of other federal and state law. The PUC’s
willful blindness to disability laws prohibiting its attempt to mandate smart meters,
constitutes legal error that must be corrected.

66 Available at https://www.ada.gov/taman2.html#II-3.7200.
28

F. The PUC’s “Burden of Proof” is Inconsistent with the Disability laws
The proper outcome does not depend on whether a smart meter “causes”
someone to suffer “adverse health effects.” The applicable law turns on entirely
different considerations. The only questions are whether someone has a functional
“impairment” and then what accommodation is due.
1. PUC Applied Wrong Standard
The utility and PUC each argue that the Petitioners failed to “demonstrate by
a preponderance of the evidence that a ‘conclusive causal connection’ between the
low-level RF exposure from a PECO smart meter and the alleged adverse human
health effects.” 67 But the PUC/utility have consistently focused on the wrong type
of “causal connection” and demanded too much by way of “alleged adverse human
health effects.” The stated burden of proof is virtually impossible to meet for
almost any Complainant because it would require resources no average person can
amass, especially someone who is already sick and likely low-income or with
limited means. A demand for rigorous scientific and medical support for the

67 This standard was first established in Letter of Notification of Philadelphia
Electric Company Relative to the Reconstructing and Rebuilding of the Existing
138 kV Line to Operate as the Woodbourne-Heaton 230 kV Line in Montgomery
and Bucks Counties 1992 Pa. PUC LEXIS 160, at *7-8 (Pa. P.U.C., No. A-
110550F0055, filed Mar. 26, 1993). This standard is inappropriate for those who
are RF/EMF impaired since the disability laws require a different and much lower
standard.
29

proposition the Complainant has some generally-accepted disease and then direct
causation from the smart meter is unlawful for many reasons.
The determination of whether an individual is disabled is not necessarily
based on a finding that matches a generally-accepted and named disease in a
Diagnosis and Treatment Manual. The question is simply whether a person has an
“impairment” and then the effect of that impairment on the life of the individual.
42 U.S.C. §12112(a)(5)(A); 28 C.F.R. §35.108(vii).68
2. Burden of Proof Inconsistent With Disabilities Laws
Covered entities like the PUC cannot impose the level and burden of proof
applied below. Congress rejected the idea that the disability determination should
be “an onerous burden for those seeking accommodations or modifications” when
it amended the ADA and FHA. 154 Cong. Rec. S8842 (daily ed. Sept. 16, 2008)
(Statement of the Managers). The federal agencies overseeing these acts have
implemented rules of construction that make this plain. 28 C.F.R. §36.101; Part 36,

68 The analysis for a disability or handicap is the same for each of the three ADA Titles, FHA handicap purposes and Rehabilitation Act claims. That is why courts routinely address discrimination claims together. Friedman v. Cent. Me. Power
Co., No. 2:20-cv-00237-JDL, 2021 U.S. Dist. LEXIS 62585, at *5 n.2 (D. Me. Mar. 31, 2021), citing Astralis Condo. Ass’n v. Sec’y, U.S. Dep’t of Housing &
Urban Dev., 620 F.3d 62, 66 (1st Cir. 2010), Calero-Cerezo v. U.S. DOJ, 355 F.3d
6, 19 (1st Cir. 2004) and Theriault v. Flynn, 162 F.3d 46, 53 n.10 (1st Cir. 1998)
(Lipez, J., concurring). Pennsylvania generally uses the same tests and criteria for
purposes of the PHRA. See Lazer Spot, Inc. v. Pa. Human Rels. Comm’n, 184 A.3d
200 (Pa. Commw. Ct. 2018).
30

Appendix C - Guidance to Revisions to ADA Title II and Title III Regulations
Revising the Meaning and Interpretation of the Definition of “Disability” and
Other Provisions in Order to Incorporate the Requirements of the ADA
Amendments Act. An individualized assessment is necessary,69 but the Guidance
directly states that once there is an individualized professional assessment “there is
no need for further inquiry into the nature of the disability:”
…Reports from experts who have personal familiarity with the candidate should take precedence over those from, for example, reviewers for testing agencies, who have never personally met the candidate or conducted the requisite assessments for diagnosis and treatment.70
None of the utility’s expert witnesses performed an in-person individualized
assessment of any of the Complainants before the Court. Doctor Israel did his
“evaluation” remotely and merely compared reported symptoms to “databases” and
“studies.” Murphy Order, p. 61 (R.190a). Thus, the PUC erred by giving the
utility’s testimony overriding weight to that from the Complainants’ medical
evidence. The PUC also erred in its evaluation of the Complainants’ evidence. The
69 See 28 CFR Appendix A to Part 36 - Guidance on Revisions to ADA Regulation on Nondiscrimination on the Basis of Disability by Public Accommodations and Commercial Facilities: “The question of whether an individual meets the definition
of disability should not demand extensive analysis… determining whether an
impairment substantially limits a major life activity requires an individualized
assessment.”
70 AG Order No. 3181-2010, 75 FR 56258, Sept. 15, 2010; 76 FR 13287, Mar. 11,
2011. The block-quoted sentence appears at 75 FR 56297.
31

Complainants clearly described an impairment that substantially limits major life
activities and showed that installation of a smart meter would significantly
interfere with their medically-affirmed need for avoidance. In other words,
consistent with the NIBS report finding smart meters can render homes
“inaccessible” to those who are electromagnetically-sensitive.
VI. Only Reasonable and Effective Accommodation is Analog Meter
Requiring a smart meter unlawfully discriminates against those who are
exposure intolerant.71 The service here is electricity, and utilities were able to
provide that service for many decades without smart or digital meters. Allowing
opt-out for the disabled will not impose an impossible or even overly difficult
burden. The RF-impaired cannot be required to sacrifice their health, worsen their
impairments. and live in an intolerable home environment in order to have
essential utility service.
Once an “impairment” and its “limitations” are shown the question then
turns to what “accommodations” are appropriate. Here, the PUC offers an
“accommodation” in the form of moving the meter away from the home. This
“accommodation” does not resolve the problem since it will not fully prevent RF
exposure despite the additional distance from the wireless transmitting antenna.

71 Friedman v. Cent. Me. Power Co., supra held that the plaintiff had adequately
plead discrimination when he had to pay a smart meter opt-out fee. An inability to
opt-out at all is clearly worse.
32

A. Placement in Yard is Not Reasonable Accommodation
Moving the smart meter to a more distant location in the yard would reduce
the wireless RF exposure level inside the home. There would, however, still be RF
emissions in the house and on the property. Anyone with electro-sensitivity will
have to stay far away from the meter. As a result, the person will not have full use
and enjoyment of a significant part of their property. This is still unlawful
discrimination under the FHA and Rehabilitation Act, because customers who are
not electro-sensitive do have full use and enjoyment of all their property, including
the part near the utility meter. Friedman v. Cent. Me. Power Co., supra. Thus, the
proffered “accommodation” is not “reasonable” and neither the PUC nor PECO
can impose that outcome. Further, installing the meter further away merely reduces
but does not eliminate the emissions that will enter the house. The customers will
still have to expend resources to shield the house from the radiation.72
B. Placement in Yard Does Not Eliminate Harmful RF “Noise” in House
The smart meter’s AC/DC conversion process by the SMPS generates
variable RF spikes that enter the house electric wiring, transforming the house into
a whole house antenna. Installing the smart meter further away from the house

72 BBI Report ¶¶29-31.
33

would not eliminate this problem. Digital meters also contain SMPS and therefore
generate RF and cannot be considered a reasonable accommodation.73
The only reasonable and effective accommodation is an analog meter – the
kind that has been used for many decades. It does not have a SMPS and will cost
the utility less than $100.74 Accommodating the “customers” in this case and all
the hundreds of people who requested accommodation would have been cheaper
than this case.
VII. CONCLUSION
Act 129 does not compel smart meters absent customer consent; it clearly
envisions affirmative customer request (Opt-In). Regardless of the legislature’s
word choice the state cannot lawfully force a customer to accept a smart or digital
meter when mandatory installation results in disability discrimination, exacerbates
existing impairments or forces people to abandon their home. There must be
effective accommodation.
The rule is simple: accommodation in the form of an analog meter is
required if a customer presents a professional assessment of impairment and a need
for RF/EMF avoidance.

73 Engineer Report ¶¶18-19; BBI Report ¶¶27-34.
74 BBI Report ¶36.
34

The Court can dispose of this case without directly wading into health
effects or even disability by merely applying the statute according to its plain
terms. If it does go farther the Court should ensure that those with electro-
sensitivity can receive accommodation in the form of an analog meter. Any other
outcome will be inhumane. No decent society purposefully punishes the innocent
for conditions they cannot control. The Court cannot allow an outcome that will
lead to even more sickness and homelessness for those who cannot tolerate a smart
or digital meter.

Respectfully Submitted,
/s/ Andrea L. Shaw Andrea L. Shaw (I.D. No. 89333) Law Office of Andrew H. Shaw, P.C. 2011 W. Trindle Road Carlisle, PA 17013 Tel: [phone]
Fax: [phone]
[e-mail]

Robert F. Kennedy, Jr.* Children’s Health Defense 48 Dewitt Mills Road 1227 North Peachtree Pkwy, Suite 202 Peachtree City, GA 30269 Tel: [phone]
Fax: [phone]
NY Bar No. 1999994
[e-mail]

35

W. Scott McCollough* McCollough Law Firm, P.C. 2290 Gatlin Creek Rd. Dripping Springs, TX 78620 Tel: [phone] Fax: [phone]
Texas Bar No. 13434100
[e-mail]

*Pro hac vice motion pending

36

APPENDIX
LIST OF ADDITIONAL AMICI CURIAE

PENNSYLVANIANS FOR SAFE TECHNOLOGY is a volunteer grassroots
organization that seeks to educate and inform Pennsylvanians about ways to
protect health and the environment through the safer, more secure use of
technology, especially wired connections.
PENNSYLVANIA SMART METER WORK GROUP is an organization in
Pennsylvania which acts as a support group for utility customers with Formal
Complaints entered with the PA Public Utilities Commission objecting to the
installation of smart meters on their properties. Their members, pro-se litigants,
help each other get through the legal and bureaucratic tangle of utility and
administrative law. Their mission has broadened to include 5G and other
wireless devices and systems as the ramifications of wireless extend beyond
smart meters.
NATIONAL ASSOCIATION OF ENVIRONMENTAL MEDICINE is a
501(c)(6) national medical organization based in Washington that provides
clinical guidelines and specialization in environmental medicine for naturopathic
physicians and allied primary care providers.
37

MOMS ACROSS AMERICA is a 501(c)(3) nonprofit organization with national
networks based in North Carolina which reaches millions of people every month.
Its mission is to educate and empower mothers and others with actions and
solutions to create healthy communities.
NATIONAL ASSOCIATION FOR CHILDREN AND SAFE TECHNOLOGY
is an organization whose mission statement is to advance policies regarding
technology that protect children’s health and well-being in order to ensure a
strong future for the United States of America.
MASSACHUSETTS FOR SAFE TECHNOLOGY is a public interest advocacy
group based in Massachusetts and is a project under the 501(c)(3) nonprofit
Concerned Citizens for the Appropriate Placement of Telecommunications
Facilities, Inc., which serves as its fiscal agent. Its mission is to educate citizens,
public servants, lawmakers and health care professionals on the risks of wireless
radiation exposure to children, adults and our environment and to promote the
use of biologically safe and fiscally responsible technology in our homes,
schools, communities, and workplaces.
38

VIRGINIANS FOR SAFE TECHNOLOGY LLC is based in Virginia. Its
mission is to advocate for safe, accessible, affordable, and ethical technology for
all and provide information, education, resources, and support to empower
consumers and lawmakers to make informed decisions and act as stewards of
their communities.
NEW YORK SAFE UTILITY METER ASSOCIATION is a nonprofit
corporation whose mission is dedicated to the continued use of mechanical
analog utility meters. NYSUMA educates the public about the hazards
associated with electronic digital utility meters (aka: AMR, ERT, AMI, "smart,"
and "opt-out digital"). They are also very concerned about the unchecked privacy
invasion of digital utility meters and skyrocketing utility rates. NYSUMA
advocates for the rate payer’s right to choose the safest meter without penalties.
NYSUMA also works to raise awareness about the dangers of other wireless
radiation technologies, including Wi-Fi, cell phones, 3G, 4G, 5G cell towers and
their negative impact on public health and the environment.
RHODE ISLANDERS FOR SAFE TECHNOLOGY is an organization based in
Rhode Island that envisions a world in which computer and telecommunications
technology is safer. Its mission is to educate the public regarding wireless health
risks and best practices.
39

ARIZONANS FOR SAFE TECHNOLOGY is a group seeking to protect
Arizona neighborhoods through better, safer technologies.
UTILITY METER CHOICE FOR 4 MICHIGAN is an organization whose
mission is to inform the public of the harm of wireless radiation from smart
meters and pass legislation which will provide utility customers with the right to
choose not to be exposed to the dangers caused by smart meters.
MARYLAND SMART METER AWARENESS is a 501(c)(3) nonprofit
corporation out of Baltimore, MD, whose mission includes education of the
public regarding smart meters, wireless technology and the health impacts of
radio frequency microwave radiation, as well as to provide and advocate for
alternatives to wireless smart meters and to engage in litigation to protect
Maryland residents from the harmful effects of smart meters. They have about
1,000 members.
AUTISM AGE is a 501(c)(3) nonprofit corporation based in Connecticut that
gives voice to those who believe autism is an environmentally-induced illness
that is treatable, and that children can recover. They believe that autism is the
defining disorder of our age, is man-made and therefore preventable. Smart
meters are an environmental risk to health that is preventable.
40

COLORADANS FOR SAFE TECHNOLOGY is an advocacy group based in
Colorado whose mission is to educate the public and public representatives of the
risks and downsides of wireless technology and to promote the implementation
of safe, efficient alternatives.
SAFE TECHNOLOGY MINNESOTA, a project of the 501(c)(3) nonprofit
corporation Minnesota Natural Health Coalition, has as its mission to educate
and support the public regarding the health and environmental hazards of
electromagnetic radiation, especially from wireless technology.
CONNECTICUT RESIDENTS FOR RESPONSIBLE TECHNOLOGY is a
grassroots organization based in Connecticut consisting of 1,500 members, most
of whom have suffered from radiofrequency radiation. Their mission is to
increase community awareness of the negative health effects of macro cell
towers in close proximity to homes, schools, health centers and workplaces, and
to stop the irradiation of citizens.
MICHIGAN FOR SAFE TECHNOLOGY is an organization in Michigan whose
mission is to educate, inform, and advocate for the safe use of wireless
technology.
41

IDAHOANS FOR SAFE TECHNOLOGY FOUNDATION is a 501(c)(3)
nonprofit corporation whose mission is to provide educational and financial
support for statewide efforts toward deployment of responsible broadband
technology to our communities and throughout the State of Idaho.
MALIBU FOR SAFE TECH is an organization in California that consists of
active local residents fighting to protect the community and environment from
the threats of wireless telecommunication. Its mission is to raise awareness of
these immediate issues and actively participate in local government to stop the
spread of 5G before its effects become detrimental to residents.
MANHATTAN NEIGHBORS FOR SAFER TELECOMMUNICATIONS is an
educational initiative whose mission is to bring awareness to the harmful
physical and mental health effects of cell phones, Wi-Fi, wireless computer
equipment, portable phones, excessive screen time, too-early technology use,
wireless utility equipment and neighborhood cell towers and antennas.
ELECTROMAGNETIC SAFETY ALLIANCE, INC. is a 501(c)(3) nonprofit
corporation based in Arizona whose mission is to advocate for and educate others
about the health risks of electromagnetic fields. Their fiscal sponsor is Vitalyst
Health Foundation.
42

ALLIANCE FOR MICROWAVE RADIATION ACCOUNTABILITY, INC.
(AMRA) is a nonprofit corporation based in New York that seeks to improve
public health and safety through the advocacy of tougher standards and safer
technology. AMRA works for greater awareness of Microwave Radiation
Syndrome and the health impact on its victims.
A VOICE FOR CHOICE ADVOCACY, INC. is a 501(c)(4) nonprofit
corporation based in California that advocates for people’s rights to be fully
informed about the composition, quality, and short- and long-term health effects
of all products that go into people’s bodies, such as food, water, air,
pharmaceuticals, cosmetics, as well devices such as smart meters.
SAFE TECH FOR SANTA ROSA is an advocacy group in California whose
mission is to post relevant information about current and planned wireless
transmission facilities and "small" cell sites in Santa Rosa, California and
provide resources on the biological effects of microwave radiation as supported
by scientific studies.
SAFE TECH SANTA BARBARA COUNTY is an unincorporated association
and advocacy group whose mission is to educate the community about the
adverse cumulative effects of invisible wireless Radio Frequency Radiation
(RFR) and advocate for safe technology.
43

SAFE TECH TUCSON is comprised of residents, business owners and respected
members of the various communities within Pima County and the City of Tucson
who are committed to working in partnership with elected officials to enact a
telecommunications ordinance that protects public safety, privacy and property
values.
BEE HEROIC LLC is a nonprofit, limited liability company located in Colorado
whose mission is to provide an information-to-action platform for initiating
practices that will save and protect Earth's bees and other pollinators from near-
term extinction. It is focused on agrochemical threats,
telecommunication/5G/IoT, and other environmentally and biologically
destructive industries that contribute to the mass extinction of a key indicator
species.
CALIFORNIA BRAIN TUMOR ASSOCIATION is a 501(c)(3) nonprofit
organization whose mission is to educate the public about environmental health
threats including those from exposure to electromagnetic radiation.
CALIFORNIANS FOR RENEWABLE ENERGY (CARE) is a 501(c)(3)
nonprofit corporation whose purpose is to offer legal advice and appear before
administrative bodies to help enforce environmental laws through court actions.
44

CENTERVILLE CONCERNED CITIZENS is a grassroots advocacy group in
Massachusetts focused on advancing environmental health and protecting the
community of Centerville. It was founded to stop the powering of a
telecommunications cell tower in the historic village of Centerville. The initial
group of nine neighbors has grown to hundreds of supporters who work to keep
the community free of dangerous, untested wireless technology. “We have
children and grandchildren that will one day look to us and be grateful we fought
so strongly for their future health and well-being.”
CLEAR WIDBY is an organization in Washington state. CLEAR (Citizen
League Encouraging Awareness of Radiation) is dedicated to the safety from
electronics of wildlife, flora, fauna, and insects that experience 24/7 radiation
from towers, as well as from humans who carelessly install and use their
electronics. They assist citizens with wireless issues: town and county
ordinances, 5G developers, smart meter issues, wildlife protection from EMF
excesses, helping the human population use wireless more safely, calling for
increased protections for the electromagnetically sensitive, and encouraging
fiber-optic hookups for broadband coverage for all.
COALITION AGAINST SMART METERS AND 5G is an organization in the
state of Washington whose purpose is first to prevent installation of smart meters
45

in Snohomish County, Washington, and also to prevent installation of 5G small
cell towers in Edmonds, Washington.
FRIENDS OF MERRYMEETING BAY is a Maine-based 501(c)(3) nonprofit
engaged in research, advocacy, education, and land conservation. Because of its
inordinate proliferation and its biological effects on people and the environment,
FOMB considers radiofrequency radiation (RFR) the most significant
environmental toxin of our time. Smart meters dramatically increase rural
presence and effects of RFR. FOMB filed an Amicus Curiae Brief with the
Commonwealth Court in support of petitioners Povacz, Murphy, Randall and
Albrecht (NO. 606 CD 2019).
ECOLOGICAL OPTIONS NETWORK is a 501(c)(3) nonprofit organization in
California. Since 1999 they have been actively organizing, informing, and
producing media and to influence policy that protects people’s right to health in
the midst of cell towers, cell phones, smart meters, and 5G. They organized in
their county and region for a smart meter opt-out. They also served as official
public intervenors in the smart meter proceeding at the California Public Utilities
Commission.
DAMS (Dental Amalgam Mercury Solutions), INC. is a 501(c)(3) nonprofit
corporation based in Minnesota whose mission is to educate the public about
46

biological dentistry and the dental-health connection. It is also concerned about
the proliferation of wireless radiation causing biological harm. DAMS has about
2,000 members, and approximately half are health care professionals.
EMF WELLNESS LLC is a 501(c)(3) nonprofit corporation in Arizona
comprised of residents, business owners and members of the various
communities within Pima County and the City of Tucson who are committed to
working in partnership with elected officials to enact a telecommunications
ordinance that protects public safety, privacy, and property values.
DR. OLINDO FLORO PA is a clinical practice out of Minnesota that provides
natural health care and education to their patients so that they can be happy,
healthy and pain free. They educate and treat patients that have symptoms of
wireless radiation exposure.
EARTH PROTECTOR LICENSING CORPORATION is a 501(c)(3) nonprofit
environmental and health organization based in Minnesota whose mission is to
improve life and to be an earth protector. It is concerned about the proliferation
of wireless technology, including smart meters, and the harmful effects of this
radiation.
47

ENVIRONMENTAL HEALTH COMMITTEE is a nonprofit organization in
New York with a mission to educate the residents of the Butternut Valley on the
dangers of, and ways to mitigate, environmental pollution from all sources,
currently focusing on the dangers of wireless microwave radiation-emitting
devices.
5G FREE CALIFORNIA is a 501(c)(3) nonprofit corporation based in California
whose mission is to engage in education, outreach and advocacy on the health
effects of wireless radiation and on support for safer technology; to enhance the
vision that people have the right to be protected from harm and that those already
injured are acknowledged, respected and supported; and that people have the
right to make informed choices about exposure to radiation and health
sovereignty.
5G FREE MARIN is a nonprofit coalition in California composed of local
Marin-based groups fighting to stop unnecessary, unsafe and excessive wireless
technologies from being imposed on local communities by the
telecommunications industry.
5G FREE OREGON is a nonprofit volunteer organization based in Portland,
Oregon, dedicated to raising awareness of the critical issue of radio and
microwave radiation technologies and their adverse effects on health.
48

5G FREE RHODE ISLAND is a group of private individuals with a common
interest in protecting humans and the environment from the harms of wireless
radiation. Its mission is to continue to actively educate communities and public
officials at the city, state, and federal levels. It takes action in furtherance of the
foregoing by holding their cities and towns accountable for protecting all
residents and stopping the 5G rollout.
FOUNDATION FOR ADVANCEMENT IN CANCER THERAPY is an
educational 501(c)(3) nonprofit corporation. Their goal is to educate physicians
and patients about a different concept of treatment and prevention of cancer and
chronic degenerative conditions. They are concerned about the health impacts of
electromagnetic radiation-producing devices such as smart meters.
HANDS ACROSS THE RIVER COALITION is incorporated in the state of
Massachusetts with about 600 members. Their primary focus is the health-
conscious cleanup of the New Bedford Harbor Superfund site contaminated
primarily with PCBs which can affect public health. Their fiscal sponsor is
People Acting in Community Endeavors, PACE, in New Bedford, MA. They are
concerned about smart meters and other emitters of harmful electromagnetic
radiation.
49

KEEP BALDY WILD is an organization based in California that is committed to
projects and education that support the unique ecosystem of the San Antonio
Canyon watershed for current and future generations. Their group distributed the
summary of the BioInitiative Report of 2012 to community members and did
educational outreach regarding smart meters, cell phones and cell towers.
KEEP CELL ANTENNAS AWAY is an informal group of residents in
California, united by a common goal of keeping cell antennas away from homes.
Their mission is to influence 5G roll-out in their cities by building a large and
active movement of residents.
KEEP YOUR POWER is an advocacy group in Hawaii that consists of a
coalition of educated, concerned citizens whose mission is to stop harmful
wireless technologies from being deployed in the Hawaiian islands and to
advocate for safe technology.
KUNZE PRODUCTIONS, LLC is a for-profit company based in California
which presents an investigative documentary called “Mobilize” that explores the
potential long-term health effects from cell phone radiation, including cancer and
infertility.
50

LAST TREE LAWS is an informal group for advocacy based in Massachusetts
and is also organized as a Massachusetts state ballot question committee,
focusing on lobbying and ballot question work. Its mission is to lobby for
environmental and social justice, as well as reducing wireless exposures.
NATIONAL HEALTH FEDERATION (NHF) is a 501(c)(3) nonprofit
organization whose mission is to educate consumers, producers, healthcare
professionals, government and other leaders regarding freedom of choice and
informed consent in healthcare, and to protect the health rights and freedom of
individuals and healthcare practitioners regarding freedom of choice and true
informed consent in all matters concerning healthcare.
NATIONAL TOXIC ENCEPHALOPATHY FOUNDATION is a 501(c)(3)
nonprofit organization whose mission is to provide education and services to the
growing segment of the population who are adversely affected by everyday
chemicals and toxins in our environment, and to provide education on cell phone
safety that is showing a correlation with the increase of brain tumors and cancer.
NEVADA CITY TELECOMMUNICATIONS ORDINANCE PUBLIC
WORKING GROUP is a group of individuals in Nevada, California, whose
mission is to amend the city's telecommunication ordinance and strengthen the
City’s legal authority to protect residents and the quiet enjoyment of their streets.
51

NEW YORKERS 4 WIRED TECH is a group of grassroots advocates in New
York whose mission is to alert the public to the serious biological harm caused
by wireless communications infrastructure’s pulsed-modulated microwave
radiation, and support municipally-owned and controlled wireline solutions (fiber
optic broadband direct to homes and businesses as a basic public infrastructure, a
public necessity and a public good) in the public rights-of-way. It advocates for
the preservation and maintenance of existing legacy copper, switched telephone
landlines.
NORTH CENTRAL WEST VIRGINIA FOR SAFE TECHNOLOGY is a
nonprofit organization in West Virginia whose mission is to reflect the feelings
and actions of like-minded people in West Virginia and around the world, to
make our area on the planet one of the healthiest (low radiation) places to live in
the USA.
ONCE A FOREST is a community organization based in Santa Fe, NM,
supporting living forests and community-inclusive decision-making about forest
health with a mission to inform the public about forest service cut and burn
plans. They are concerned about the impact of harmful electromagnetic radiation
on the health of the forests.
52

ORGANIC CONSUMERS ASSOCIATION is based in Minnesota and is an
online and grassroots 501(c)(3) nonprofit public interest organization, and the
only organization in the U.S. focused exclusively on promoting the views and
interests of the nation's estimated 50 million consumers of organically and
socially responsibly produced food and other products. Their mission statement
is to protect and advocate for consumers' right to safe, healthful food and other
consumer products, a just food and farming system and an environment rich in
biodiversity and free of pollutants.
PATRONS OF THE PLANET is an environmental group in Connecticut
working to bring awareness and information to residents about the importance of
protecting the lands, water, insects and air from the harmful effects of “small
cells,” cell towers and smart meters. They advocated against a bill that would
extend the rollout of “small cells.”
PLUMAS WIRED! is an advocacy group of Plumas County residents in
California, with hundreds of members, whose mission is to support safer,
affordable, wired telecommunications for the public.
SAINT CROIX APPRAISALS is an organization that offers appraisal services
for residential homes and educates people about the destructive effects of Wi-Fi
and electromagnetic energies in their homes.
53

SANTA BARBARA PERMACULTURE NETWORK is a 501(c)(3) nonprofit
organization in California that helps Santa Barbara design systems to reconcile
human communities with the ecological imperatives of a living planet.
SECOND LOOK is a nonprofit organization whose main goal is to facilitate full
public and scientific examinations of public policy issues that have become
obscured by media treatment (or lack thereof), or by political rhetoric, or because
of the inaccessibility of accurate information to relevant constituencies. Their
primary environmental health concerns are fluoride toxicity, fluoride poisoning
in individuals, and electromagnetic field toxicity science.
SOCIAL JUSTICE COMMITTEE is a faith-based committee of the Berkeley
Fellowship of Universalist Unitarians, a 501(c)(3) nonprofit organization based
in California, whose mission is to support inclusion and diversity, environmental
stewardship, fair labor practices, and general peace, democracy, and human
rights in the U.S. and abroad.
SOUTH CAROLINA COALITION FOR WIRELESS SAFETY STANDARDS
is a 501(c)(3) nonprofit corporation whose mission is to educate and advocate on
the dangers that wireless technology poses to human health and the environment.
The SCCWSS represents thousands of people across South Carolina. The
Coalition embraces and supports getting safe, connected technology to every
54

citizen in South Carolina while reducing the man-made electromagnetic pollutant
of radio frequency, microwave and millimeter wave radiation.
STOP 5G CARLSBAD is a grassroots movement of residents in Carlsbad,
California who are deeply concerned about the pending construction of 5G
“small cell” towers every 300-500 feet throughout their neighborhoods. They are
also concerned with such harmful devices as smart meters.
STOP 5G ENCINITAS is a California organization that envisions and seeks to
ensure a world where 4G, 5G, 6G or any other "G" is implemented by safe
technology standards that has undergone scrutiny to ensure the health and well-
being of all life on the planet before being unleashed. They also envision and
seek to ensure a world where the health and well-being of all life takes
precedence over corporate self-gain.
STOP 5G INTERNATIONAL is a voluntary association of individuals from
around the world with about 5,000 members from multiple countries whose
mission is to support the global effort to stop 5G because it poses an immediate
threat to life on earth. They rely on evidence-based information and non-violent
actions in keeping with the vision of Stop 5G International. Their financing is
through Ecological Options Network, a 501(c)(3) organization.
55

STOP 5G JAX is an activist group of citizens whose mission is education and
opposition to 5G in Jacksonville, FL and in the rest of Florida.
STOP SMART METERS! is based in California and their fiscal sponsor is
California for Renewable Energy. It is an advocacy, media outreach and direct
action network providing activism, consultation and advice to dozens of local
groups who are opposing wireless smart utility meter deployments for health,
privacy, safety and other reasons.
STOP SMART METERS NEW YORK was created in 2013 as an information
hub and help line for New York State residents who are concerned about the
forced installation of digital utility meters in the state. This step was required due
to the absence of any state-provided consumer protection for utility
customers. Their mission is to secure a no-fee safe analog utility meter choice
for all New York State residents.
SWEETWATER COLLABORATIVE is a 501(c)(3) nonprofit from California
whose mission is to demonstrate how to live in balance with their local
watershed using regenerative, waterwise landscape practices. They provide
education, workshops, and training for sustainable water management as well as
consultations, design, and installations of greywater and rainwater harvesting
systems, food forests and drought-tolerant and edible landscapes. They work
56

with homeowners, organizations, businesses and neighborhoods in a variety of
capacities. They are concerned about the impact of wireless radiation on
landscapes and ecosystems.
TOXICS INFORMATION PROJECT (TIP) is a 501(c)(3) nonprofit corporation
based in Rhode Island which strongly opposes deployment of 5G systems and
informs residents about the high radiation installations and their dangerous and
unhealthy effects.
VERMONTERS FOR A CLEAN ENVIRONMENT is an organization whose
mission is fighting for the economic well-being of all Vermonters assuring
appropriate use of their resources — our people, our land, our air and our water.
They are united in the belief that Vermont’s future lies in conserving its clean,
rural, small-town environment. They have joined together to pursue the common
goals of encouraging economic development with minimal environmental
impacts and preserving Vermont’s natural beauty. VCE is committed to
providing facts and information so that people can make informed decisions.
WINDHEIM EMF SOLUTIONS is an organization from California that believes
that fewer electromagnetic fields lead to better health and longer life.
57

WIRE AMERICA is a citizen journalist and advocacy organization in California,
working to preserve local control over wired broadband and wireless
telecommunications infrastructure. Local communities must retain the freedom
to integrate the best broadband options for their residents. It has worked at the
federal, state and local levels to tame the unnecessarily dense deployment of
4G/5G so-called “small” wireless telecommunications facilities (sWTFs) in
residential neighborhoods.
WiRED is an organization based in California that exists to educate the public
about wireless radiation and to defend communities against it. They are the local
embodiment of a state-wide, national and worldwide movement advocating for
safer technology and resisting the corporate imposition of wireless and cellular
technologies on the public without fully-informed consent. They seek to inform
the public via independent, evidence-based, peer-reviewed scientific studies.
They seek to awaken and empower ordinary folks to unite to take back the
autonomy of our communities from the colonizing control of transnational
telecommunications corporations.
WIRED BROADBAND, INC. is a nonprofit corporation in New York whose
mission is to educate the public and government officials about the dangers
associated with radio frequency radiation from wireless facilities and to advocate
58

for the use of fiber optics as a safer, faster and more secure solution to broadband
deployment in New York City and throughout the United States.
WIRELESS EDUCATION ACTION is an educational organization based in
Oregon whose mission is education regarding the potential health effects of
wireless technology and how to reduce exposure, education of local and federal
representatives, and of health practitioners. They wish to build a greater and
greater grass root movement to affect change in Oregon.
WIRELESS RADIATION EDUCATION & DEFENSE is a grassroots nonprofit
organization based in California composed of concerned scientists, educators,
parents, and activists. This organization is a fiscal project of Ecological Options
Network (EON), which is a 501(c)(3) nonprofit corporation. Its mission is to
empower the public to regain autonomy and rights over adverse
telecommunication company interests.
59

CERTIFICATE OF COMPLIANCE
Pursuant to Pa. R. App. P. 531(b)(3) and 2135(d), the undersigned certifies
that this Brief complies with the type-volume limitations of Pa. R. App. P.
531(b)(3) because this Brief contains 6,985 words, excluding those parts
exempted by Pa. R. App. P. 2135(b).

/s/ Andrea L. Shaw Andrea L. Shaw (I.D. No. 89333) Law Office of Andrew H. Shaw, P.C. 2011 W. Trindle Road Carlisle, PA 17013
Tel: [phone]
Fax: [phone]
[e-mail]
Counsel for Amici Curiae
60

CERTIFICATION OF CONFIDENTIAL INFORMATION
I hereby certify that this filing complies with the provisions of the Case
Records Public Access Policy of the United Judicial System of Pennsylvania that
require filing confidential information and documents differently than non-
confidential information and documents.
/s/ Andrea L. Shaw Andrea L. Shaw (I.D. No. 89333) Law Office of Andrew H. Shaw, P.C. 2011 W. Trindle Road Carlisle, PA 17013 Tel: [phone] Fax: [phone]
[e-mail]

Counsel for Amici Curiae

61
CERTIFICATE OF SERVICE
I hereby certify that on this 14th day of September 2021, I electronically filed
the foregoing with the Clerk of Courts using the PACFile appellate court electronic
filing system, which will send notice of such filing to all registered PACFile users.
/s/ Andrea L. Shaw Andrea L. Shaw (I.D. No. 89333) Law Office of Andrew H. Shaw, P.C. 2011 W. Trindle Road Carlisle, PA 17013 Tel: [phone] Fax: [phone]
[e-mail]
Counsel for Amici Curiae
ADDENDUM
62
ADDENDUM
TABLE OF CONTENTS
Physicians Statement …………………………………………………... 64
Exhibit 1 ………………………………………………………….. 86
Exhibit 2 …………………………………………………………. 122
Scientists Statement ……………………………………………………. 136
Engineer Report ……………………………………………………….. 168
Building Biology Institute Report ……………………...……………… 184
63
PHYSICIANS STATEMENT
64
IN THE SUPREME COURT OF PENNSYLVANIA
MIDDLE DISTRICT
RE: No. 34 MAP 2021, Povacz, M, et al. v. PUC
Associated Case(s):
35 MAP 2021 Consolidated
36 MAP 2021 Consolidated
37 MAP 2021 Consolidated
38 MAP 2021 Consolidated
39 MAP 2021 Consolidated
40 MAP 2021 Consolidated
41 MAP 2021 Consolidated
42 MAP 2021 Consolidated
43 MAP 2021 Consolidated
44 MAP 2021 Consolidated
45 MAP 2021 Consolidated

PHYSICIANS STATEMENT
SMART METER EFFECTS ON PATIENTS WHO ARE ADVERSELY AFFECTED BY
EXPOSURE TO RADIOFREQUENCY AND ELECTROMAGNETIC EMISSIONS

Purpose of Statement
1. The undersigned are physicians - medical doctors (MDs) and Doctor
of Osteopathic Medicine (DOs). Our duty as physicians is to help our patients and
protect our community’s public health. The American Medical Association’s Code
of Medical Ethics also demands that we seek legal outcomes that are in the best
interests of the patient. Code of Medical Ethics Opinion 8.1 states that “While a
physician’s role tends to focus on diagnosing and treating illness once it occurs,
physicians also have a professional commitment to prevent disease and promote
65
health and well-being for their patients and the community.” Our Hippocratic Oath
requires that we take all necessary steps to “prevent disease whenever we can.”
Our professional ethics therefore demand that we participate in efforts to prevent
patient harm.
2. We file this statement to share with the Court our knowledge of the
scientific and medical literature and our experience working with those of our
patients, adults and children, who are adversely affected by exposure to wireless-
based technologies, including smart meters. Combined we have over 3,000 patients
who suffer from electro-sensitivity and/or other conditions which are aggravated
by exposure. We hope our statement will help the Court reach an informed and
equitable decision in this extremely important case that may have widespread
implications on the lives of those adults and children who are adversely affected
across the country.
3. It is our unequivocal opinion that Smart meters must not be forced on
patients who experience a negative response to RF/EMF, and the only reasonable
and humane accommodation is analog meters, the same meters we have had for
many decades.
Introduction and Summary of Filing
4. Wireless-based technologies such as cell phones, Wi-Fi and smart
meters use and emit pulsed electromagnetic fields (EMFs) and radiofrequency
66
(RF) radiation (collectively RF/EMF). Exposure to RF/EMF can be harmful, at
least to some people. It can directly injure; it can exacerbate pre-existing
conditions; and it can interfere with treatment.
5. The undersigned doctors have patients who suffer adverse reactions to
RF/EMF, and some of the undersigned doctors themselves are adversely affected
and personally experience the painful and debilitating effects of exposure.
6. Adverse effects from RF/EMF are real, proven and a major threat to
some people’s health. Human physiology has many bioelectric elements, and this
is especially true of the heart, brain, nervous system, and intercellular
communication. Pulsed and modulated RF/EMF are stressors that directly affect
this physiology. Humans vary in their physiology and in their resilience to
stressors. Some people lose the ability to cope at a lower level of exposure to
toxins than others and some may never get sick.
7. The only treatment for those who suffer impairments worsened by
RF/EMF exposure is avoidance. However, with the ever-growing ubiquitous,
involuntary exposure to RF/EMF from wireless technology and infrastructure,1
their home environment is the only place they have some ability to control
exposure. It is their last place of refuge.
1 https://www.thelancet.com/journals/lanplh/article/PIIS2542-5196(18)30221-
3/fulltext.
67
8.Mandatory smart meter deployment in homes, without a meaningful
accommodation for those adversely affected by RF/EMF, will frustrate our ability
to maintain or improve our patients’ well-being; cause them intolerable harm; and
take away from them their only possible refuge, the only place to which they have
some control over exposure, and which must be a sanctuary.
9.For those who are adversely affected, having a wireless or digital
smart meter is not an option. The only reasonable accommodation is an analog
meter. It does not create the adverse elements on the electric system created by the
operation of the digital/wireless “smart” meters that adversely affect them.
Electro-Sensitivity
10.The most widespread sickness associated with exposure to pulsed
RF/EMF is likely “electro-sensitivity.”2 The condition is also referred to in the
scientific literature as “electromagnetic hypersensitivity” (EHS), “microwave
sickness” and “radiation sickness.”
11.The condition is characterized by a constellation of mostly
neurological symptoms that occur as a result of exposure to RF/EMF. Common
symptoms include headaches, cognitive and memory problems, exhaustion, heart
palpitations, anxiety-like symptoms, seizures, sleep issues, ringing in the ears,
2 https://www.aaemonline.org/wp-
content/uploads/2020/12/AAEMEMFmedicalconditions.pdf.
68
tingling, nausea, skin reactions, dizziness, noise sensitivity, digestive problems,
and nosebleeds.
12. Electro-sensitivity is not truly a sensitivity; it is a sickness caused
and/or aggravated by exposure to pulsed RF/EMF, with serious physiological
complications. Many hundreds of studies have proven that RF/EMF exposure can
cause and/or aggravate these symptoms3 and the underlying injuries4 and establish
the causal mechanisms of harm.5
13. There are diagnosis guidelines and International Codes of Diseases
classifications. Doctors and scientists warn that it is widespread, and the rates are
growing. It is recognized as a disability by US agencies.6
3 Neurological effects: https://bioinitiative.org/wp-content/uploads/2020/09/6-
RFR-Neurological-Effects-Abstracts-2020.pdf; https://bioinitiative.org/wp-
content/uploads/2020/10/13-Neurological-Effects-Studies-Percent-Comparison-
2020.pdf.
4 https://direct.mit.edu/neco/article/30/11/2882/8424/Diplomats-Mystery-Illness-
and-Pulsed.
5 Mechanism of harm: https://bioinitiative.org/wp-content/uploads/2020/09/3-
RFR-Free-Radical-Oxidative-Damage-Abstracts-2020.pdf (oxidative stress);
https://direct.mit.edu/neco/article/30/11/2882/8424/Diplomats-Mystery-Illness-
and-Pulsed’; https://direct.mit.edu/neco/article/30/11/2882/8424/Diplomats-
Mystery-Illness-and-Pulsed.
6 See further discussion in the Amicus Brief. Also:
https://childrenshealthdefense.org/wp-content/uploads/rf-accomodation-nibs.pdf;
Dept. of Education: https://childrenshealthdefense.org/wp-content/uploads/rf-
accomodation-education.pdf; Dept. of Labor:
https://childrenshealthdefense.org/wp-content/uploads/rf-accomodation-labor.pdf.
69
14. For many of our patients, RF/EMF exposure adversely and severely
affects their ability to physically and mentally function. Exposure can interfere
with brain wave operation and impair blood flow to the brain. These effects can
cause interference with various brain functions including sleep and cognitive
functions. Exposure can also damage the blood-brain barrier (BBB) which can
lead to brain damage and neurodegenerative conditions. RF/EMF interfere with the
nervous system and bioelectric functions.7
15. Those affected react to RF/EMF exposures they were able to tolerate
previously and at levels that may not evoke a negative response in others. With
avoidance, the symptoms decrease and can even completely disappear. But with re-
exposure they reappear. Continued exposure leads to increase in symptom
frequency, severity and additional symptoms may appear. It can also worsen the
underlying injuries.
16. The scientific evidence explaining causation and mechanisms of harm
associated with RF/EMF injuries is now robust. Oxidative stress is an established
7 https://direct.mit.edu/neco/article/30/11/2882/8424/Diplomats-Mystery-Illness-
and-Pulsed.
70
mechanism of harm for RF/EMF-related injuries;8 known physiological biomarkers
and genetic predispositions9 help us in our diagnoses.
Diagnosis Guidelines
17.There are reliable diagnostic guidelines that we use and rely on in our
practice. In 2016 the European Academy for Environmental Medicine’s
(EUROPAEM) “EMF Working Group” developed official diagnosis guidelines:
“EUROPAEM EMF Guideline 2016 for the prevention, diagnosis and treatment of
EMF-related health problems and illnesses”10 (Exhibit 1). These guidelines were
developed by the world leading experts; they were peer-reviewed and published
and are used by doctors in the US and around the world. They provide a
comprehensive review of the scientific evidence regarding the symptoms, the
physiological damage, mechanisms of harm and biomarkers associated with
RF/EMF-related health effects, and they reference 235 peer-reviewed studies. The
guidelines are based on the Austrian Medical Association’s guidelines.11
18.When diagnosing the condition, we use the World Health
Organization (WHO) International Classification of Diseases’ Code T-66 for a
8 https://direct.mit.edu/neco/article/30/11/2882/8424/Diplomats-Mystery-Illness-
and-Pulsed.
9 https://www.hindawi.com/journals/mi/2014/924184/.
10 https://pubmed.ncbi.nlm.nih.gov/27454111/.
11 https://ecfsapi.fcc.gov/file/1092912632123/48-Attachment%2048-
%20Austrian%20Medical%20Assoc%20Guideline%20EMF%20Disease.pdf.
71
diagnosis of “Radiation Sickness” and Code W90 which recognizes that “Exposure
to Other Nonionizing Radiation” can cause injury.
19. The knowledge regarding the etiology of the condition is constantly
evolving. Professor Dominique Belpomme is a member of the EMF Working
Group that developed the diagnosis guidelines. Since 2009, he and his team have
been conducting extensive testing on people who suffer from electro-sensitivity to
identify the underlining injuries and biomarkers. They have tested over 700 people.
Some of the lab tests recommended by the EUROPAEM’s guidelines are based on
his work.12 To keep doctors appraised of the newly identified biomarkers, in 2020
he published peer-reviewed guidelines13 to reflect the most current findings and
biomarkers to help doctors diagnose, treat, and prevent this condition.14
20. We also consult with guidelines from clinics specializing in diagnosis
of RF/EMF-related injuries such as those developed by Professor Riina Bray, MD,
BASC, MSC, FFCP, MHSC. Prof. Bray leads the largest government hospital
12 https://pubmed.ncbi.nlm.nih.gov/26613326/.
13 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7139347/.
14 Belpomme’s studies provide clear evidence of physiological biomarkers indicating
serious physiological injuries, and he concludes that these findings negate the
hypothesis that electro-sensitivity could be psychosomatic or caused by a “nocebo”
effect. These studies include objective tests that measure physiological reactions, not
subjective perception, and prove that electro-sensitivity and exposure can lead to
severe injuries.
72
clinic specializing in diagnosing electro-sensitivity.15 Her diagnosis guidelines16
are based on the knowledge she and the seven doctors in the clinic accumulated
over the past 23 years seeing many hundreds of patients with electro-sensitivity
(Exhibit 2).
Clinical Diagnosis
21. Those who suffer from electro-sensitivity develop symptoms from
RF/EMF exposure. However, the underlying physical injury may be different from
one patient to another, because pulsed RF/EMF can cause various physiological
injuries.
22. For example, a peer-reviewed study on 675 subjects with electro-
sensitivity17 showed that 28% had leakage of the blood-brain barrier; 40% had
chronic inflammation indicating oxidative stress; 23% had autoimmune antibodies;
and 100% had reduced melatonin levels. Substantive scientific evidence shows that
each of these injuries can be caused by pulsed RF/EMF exposure.
23. For this reason, there is no one test for diagnosis and therefore, as
with many other conditions, the diagnosis must be clinical, involve direct
15 https://www.womenscollegehospital.ca/care-programs/environmental-health-
clinic/.
16https://www.womenscollegehospital.ca/assets/pdf/environmental/Preliminary%20
Clinical%20Guidelines%20%20for%20EHS.pdf.
17 https://pubmed.ncbi.nlm.nih.gov/26613326/.
73
evaluation of the patient, and requires medical judgment. Diagnosis is based on
identifying the underlying cause of the patient’s complaints based on symptoms
and medical history rather than on one specific test. Not all ailments have classic
signs from blood tests or imaging, and in lieu of these, a physician must use
clinical judgment to draw a reasonable and sensible conclusion based on personal
and direct observation and the scientific literature.18
24. When taking a patient’s medical history, we look for description of
situations which would be the equivalent of a blinded test, i.e., situations in which
the patient was unaware of the exposure and the appearance of symptoms was a
clear result of the exposure; and vice versa, where the source of exposure was
removed without the knowledge of the patient and the symptoms improved. We
also look for evidence of physiological reactions which are not based on subjective
perception and on “natural experiment”: if exposure elimination/reduction leads to
diminished symptoms, then avoidance is the recommended treatment.
25. When relevant and possible, we support our clinical diagnosis with
the lab tests suggested by the diagnosis guidelines. These lab tests are based on
18 We understand that the utility’s medical expert’s opinion was formed and expressed
without any direct contact or personal evaluation of the Complainants below, whereas
the Complainants’ medical evidence was based on personal knowledge, at least in part.
Remote diagnostics are contra-indicated, especially in this area. The Commission’s
decision to accept the utility’s medical evidence over that of an actual attending
physician is highly questionable. We note that the federal disabilities rules expressly
discount remote “records-only” evaluations.
74
biomarkers that have been associated with exposure to RF/EMF. For example, we
use blood tests for free radicals that indicate oxidative stress damage because
oxidative stress is a well-recognized mechanism of harm of RF/EMF exposure.19
26. Our patients’ symptoms can be very severe and debilitating and for
many, they significantly affect major life functions. This is so regardless of the
name attached to the condition or its alleged controversial nature.
Recognition
27. US agencies have recognized the condition as a disability entitled to
accommodations including: the US Access Board;20 National Institute of Buildings
Science;21 the Department of Labor;22 the Department of Education;23 and the
19 Many studies have shown that RF/EMF cause oxidative stress, and it is a
recognized underlying mechanism for EMF-related sicknesses, including electro-
sensitivity. https://bioinitiative.org/wp-content/uploads/2020/09/3-RFR-Free-
Radical-Oxidative-Damage-Abstracts-2020.pdf;
https://pubmed.ncbi.nlm.nih.gov/26151230/.

20 https://childrenshealthdefense.org/wp-content/uploads/rf-accomodation-access-
board.pdf#page=3.
21 The report concludes that RF/EMF is an “access barrier” and can render buildings
“inaccessible” to those with electro-sensitivity and provides accessibility guidelines.
https://www.access-board.gov/research/building/indoor-environmental-quality/;
https://childrenshealthdefense.org/wp-content/uploads/rf-accomodation-nibs.pdf.
22 https://childrenshealthdefense.org/wp-content/uploads/rf-accomodation-
labor.pdf.
23 In 2011, DOE issued a memorandum regarding accommodation of people with
Multiple Chemical Sensitivities (“MCS”). It included recommendations to minimize
exposure to EMFs and to ensure the home environment is a “sanctuary,” free from
75
Social Security Administration. In their publications some of these agencies
explain that accommodation of those affected by RF/EMF should be
removal/minimizing exposure and that their home should be a sanctuary free from
EMF.
28. In the past couple of decades, and mainly in the past 10 years, the
number of patients we see in our clinics who suffer greatly from RF/EMF has
grown.24 This is not surprising given the exponential increase in wireless
deployment and use. The general public faces constant saturation in all public
places and in the workplace.25
29. This sickness has been recognized by courts and by many medical and
official international organizations such as the Council of Europe26 and the
EMFs because they may trigger symptoms. https://childrenshealthdefense.org/wp-
content/uploads/rf-accomodation-education.pdf#page=5.
24 See statement from the American Academy of Environmental Medicine:
https://www.aaemonline.org/wp-
content/uploads/2020/12/AAEMEMFmedicalconditions.pdf.
25 https://www.thelancet.com/journals/lanplh/article/PIIS2542-5196(18)30221-
3/fulltext.
26 Resolution 1815 (2011) Section 8.1.4: “pay particular attention to “electrosensitive”
people who suffer from a syndrome of intolerance to electromagnetic fields and
introduce special measures to protect them, including the creation of wave-free areas
not covered by the wireless network.” Available at
http://assembly.coe.int/nw/xml/XRef/Xref-XML2HTML-en.asp?fileid=17994&.
76
European Parliament which stated in a resolution that the rates of electro-
sensitivity are growing “exponentially.”27
30. In 2019, the New-Hampshire legislature voted unanimously to
establish a committee to study the effects of 5G and wireless radiation. The
committee was comprised of scientists, public officials, and representatives of the
wireless industry (through CTIA, the wireless industry lobby association).
Following a year of hearing expert testimony and reviewing the science, the
committee’s majority report, published in October 2020, concluded that wireless
radiation can be harmful. The report acknowledged electro-sensitivity and the need
to accommodate those who suffer from the condition. It emphasized the need to
educate doctors.28
31. Indeed, doctors’ awareness of RF/EMFs harms is constantly growing.
The California Medical Association passed a Resolution which highlighted
RF/EMF effects consistent with electro-sensitivity. In 2021, close to 200
physicians participated in a medical conference about health effects associated
27 European Parliament Written declaration on the recognition of multiple chemical
sensitivity and electrohypersensitivity in the International Statistical Classification of
Diseases and Related Health Problems. Available at
https://www.europarl.europa.eu/doceo/document/DCL-7-2012-
0014_EN.pdf?redirect.
28http://www.gencourt.state.nh.us/statstudcomm/committees/1474/reports/5G%20
final%20report.pdf.
77
with RF/EMF exposure.29 Participants received continued medical education
(CME) credits.
32. We have no doubt that for some of our patients, RF/EMF are the
cause of their symptoms. Only those who have not had patients who are affected,
have not performed direct evaluations or are ignorant of the scientific and medical
literature and the operation of the human body, can doubt these patients and their
suffering from pulsed RF/EMFs.
Smart Meter Specific Issues
33. The problems with smart meters arise not only from the RF signal
used to wirelessly transfer the data to the utility company. A major problem is that
smart meters inject pulsed RF and extremely low-frequency (ELFs) EMFs over a
house’s electric wiring, effectively turning the entire home into a radiating antenna.
Locating the smart meter further away from the house is not an acceptable solution
or reasonable accommodation because it does not eliminate this “antenna” effect.30
34. This problem is exacerbated because the RF/EMF that enter the
electric system are intensely pulsed,31 and pulsation has consistently been
29 https://emfconference2021.com/.
30 See expert engineer Erik Anderson statement which is part of the amicus brief.
31 https://docs.cpuc.ca.gov/PublishedDocs/EFILE/BRIEF/171336.PDF.
78
identified as a central element in RF/EMF related injuries.32 EMFs used for
medical treatments are pulsed because the pulsation makes the signal more
bioactive.33
35. Some of our patients reported symptom onset after a smart meter was
installed on their homes. Many were not aware of the installation at the time, did
not suffer from adverse effects from wireless devices and had no idea that these
meters or any wireless device can cause harm. In many of the cases, the association
between the meter installation and the appearance of symptoms is clear.34
36. However, the best evidence of the adverse effects of these meters is
the changes we see almost immediately after a smart meter is removed and
replaced with an analog meter. Our patients’ symptoms usually disappear or at
least significantly lessen.
37. Adverse reactions which are not affected by subjective perception
disappear and thus the evidence is indisputable and cannot be deemed a “nocebo”
effect. It establishes clear and direct causation. For example, a common symptom
we see in patients from smart meters is nosebleeds, including in children. When the
32https://ecfsapi.fcc.gov/file/10709642227609/Carlo%20paper%20%20Real%20vers
us%20Simulated%20Mobile%20Phone%20Exposures%20in%20Experimental%20St
udies.pdf.
33 https://ecfsapi.fcc.gov/file/7520940777.pdf.
34 https://ecfsapi.fcc.gov/file/7520958363.pdf.
79
family has the smart meter removed, the nosebleeds usually disappear almost
overnight. Studies have explained the mechanism behind pulsed RF/EMF exposure
and nosebleeds.35
38. We must emphasize that the question of initial causation is irrelevant.
The smart meter may or may not be the source that first generates symptom onset.
What is relevant is that once a person begins to react to pulsed RF/EMFs, any and
all exposure must be avoided, since avoidance is the primary and only truly
effective treatment. People can turn off a cell phone, but they cannot turn off the
smart meter or shield themselves from its effects.
39. People with major life function impairments require accommodation,
without regard to initial cause. The accommodation requirement merely allows
them to better function and have some chance of a tolerable life.
40. Forcing smart meters on our patients who are adversely affected by
RF/EMF, in their homes, means exposing them 24/7 to a toxin that instigates
dysfunction, tormenting pain and severe physiological injuries and reactions, some
of which can be life-threatening.
41. Our patients and those like them cannot be required to endure
exposure that is toxic and can be even deadly to them in their own home as a
35 https://ecfsapi.fcc.gov/file/1091442657471/Cuban%20Embassy-
Beatrice%20Golomb%20PhD-Microwave%20Attack.pdf#page=20.
80
condition of utility service. If they cannot have a safe environment in their homes,
their condition will undoubtedly worsen and can result in death. Their home is
their only refuge.
42. The main recommendation to our patients beyond avoidance is to
contact professionals who specialize in EMF mitigation, to help them mitigate
RF/EMF exposure and shield the home from outside exposure sources. However,
no amount of shielding can protect those who are sick from the effects of smart
meters, since they turn the home’s electric wiring into a transmitting antenna. This
is the worst-case scenario for the electro-sensitive.
Summary
43. Based on our knowledge and experience, we unequivocally determine
that wireless and digital “smart” meters must not be forced on those who suffer
adverse reactions from RF/EMF exposure. Those who are affected must have the
choice of mechanical analog meters. Any other outcome will lead to immense
suffering and even death. It would be unconscionable.
44. This accommodation is necessary, simple and reasonable. All that is
required is to allow them to use the same mechanical analog utility meter that was
installed for many decades on homes.

Respectfully Submitted,
81

Physicians Statement Signatories

Prashanthi Atluri, MD, Cardiology, OH
Tiffany Baer, MD, Internal Medicine, TX
Sunil Bhat, DO, Family Medicine, PA
Anthony Bianco, DO, Family Medicine, OH
Michael Blahut, DO, Family Medicine, PA
Mark Brody, MD, Primary Care, Integrative Medicine, RI
Larry Burk, MD, Radiology, NC
Maria Carrascal, MD, Pediatrics, Puerto Rico
David Calderwood, MD, Family Medicine, AL
Lora Chamberlain, DO, Family Medicine, IL
Jaqueline Chan, DO, Family and Integrative Medicine, CA
Barbara A. Crothers, DO, Pathology, MD
Diane Culik, MD, Family Medicine, MI
Paul Dart, MD, Family Practice Physician, OR
82
Sandra Denton, MD, Family Medicine, Alternative Medicine, Emergency
Medicine, AK

Tim Dooley, MD, Integrative Medicine, CA
Robyn Dreibelbis, DO, Family Medicine, OR
Victoria Dunckley, MD, Psychiatry, CA
Ben Edwards, MD, Functional Medicine, TX
Erica Elliot, MD, Family and Environmental Medicine, NM
Tracy Freeman, MD, Internal Medicine, MD
Deborah Ginsburg, MD, Family Medicine, Special Needs, NJ
Melanie Gisler, DO, Family Medicine, CA
Sharon Goldberg, MD, Internal and Integrative Medicine, NM
Stephen Grable, MD, Internal Medicine, FL
Margaret Heinze, MD, Family Medicine, WI
Martha Herbert, MD PhD, Pediatric Neurologist, MA
Michael Hilts, MD, Family Medicine, NC
Jeanne Hubbuch, MD, Family Medicine, MA
Toril Jelter, MD, Pediatrics, CA
83
Lyn Johnson, DO, Family Medicine, FL
Bob Kaplan, MD, Diagnostic Radiology, AZ
Stacy Kuhns, MD, Pediatrics, PA
Christopher Lawinski, MD, Integrative Medicine, HI
Janet Levatin, MD, Pediatrics, OH
Stephanie McCarter, MD, Internal Medicine, TX
Lawrence McKnight, MD, Internal Medicine, PA
Jorge Moreno, DO, Family Medicine, CA
Leah Morton, MD, Family Medicine, NM
Gerald Natzke, DO, Assistant Clinical Professor, Michigan State University,
Environmental Medicine, Allergies, MI

Raymond Oenbrink, DO, Family Medicine, NC
Kara Parker, MD, Family Medicine, Functional Medicine, and Integrative
Health, MN

Jessica Peatross, MD, Internal and Functional Medicine, NC
Michelle Perro, MD, Pediatrics, Integrative Medicine, CA
Diane Powell, MD, Psychiatry, OR
84
Peter Prociuk, MD, Internal Medicine, PA
Kirsten Reynolds, MD, Family Medicine, WI
David G. Schwartz, MD, Family Medicine, VA
Jennifer Shaw, MD, Obstetrics and Gynecology, AZ
Pam Shervanick, DO, Psychiatry, ME
Frank Sievert, MD, Family Medicine, OR
Ana-Maria Temple, MD, Pediatrics, NC
Robert Turner, MD, Neurology, SC
Kevin Wand, DO, Family Medicine, MN
Jane Williams, MD, General Surgery, CA
Savely Yurkovsky, MD, Cardiology, Internal Medicine, Pediatrics, NY
James Ziobron, DO, Family Medicine, MI

85
PHYSICIANS STATEMENT – Exhibit 1
86
Rev Environ Health 2015; 30(4): 337–371
European Academy for Environmental Medicine (EUROPAEM) – EMF
working group:*Corresponding author: Gerd Oberfeld, Department of Public
Health, Government of Land Salzburg, Austria,
E-mail: [e-mail] Belyaev: Cancer Research Institute, Slovak Academy of Science,
Bratislava, Slovak Republic; and Prokhorov General Physics
Institute, Russian Academy of Science, Moscow, RussiaAmy Dean: American Academy of Environmental Medicine,
Wichita, Kansas, USAHorst Eger: Association of Statutory Health Insurance Physicians
of Bavaria, Medical Quality Circle “Electromagnetic Fields in
Medicine – Diagnostic, Therapy, Environment”, Naila, GermanyGerhard Hubmann: Center for Holistic Medicine “MEDICUS”, Vienna,
Austria; and Wiener Internationale Akademie für Ganzheitsmedizin
(GAMED), Vienna, AustriaReinhold Jandrisovits: Medical Association Burgenland,
Environmental Medicine Department, Eisenstadt, AustriaOlle Johansson: The Experimental Dermatology Unit,
Department of Neuroscience, Karolinska Institute, Stockholm,
Sweden
Markus Kern: Medical Quality Circle “Electromagnetic Fields in
Medicine – Diagnosis, Treatment and Environment”, Kempten,
Germany; and Kompetenzinitiative zum Schutz von Mensch,
Umwelt u. Demokratie e.V, Kempten, GermanyMichael Kundi and Hanns Moshammer: Institute of Environmental
Health, Medical University Vienna, Vienna, AustriaPiero Lercher: Medical Association Vienna, Environmental Medicine
Department, Vienna, AustriaWilhelm Mosgöller: Institute of Cancer Research Medical University
Vienna, Vienna, AustriaKurt Müller: European Academy for Environmental Medicine,
Kempten, GermanyPeter Ohnsorge: European Academy for Environmental Medicine,
Würzburg, GermanyPeter Pelzmann: Department of electronics and computer science
engineering, HTL Danube City, Vienna, AustriaClaus Scheingraber: Working Group Electro-Biology (AEB), Munich,
Germany; and Association for Environmental- and Human-Toxicology
(DGUHT), Würzburg, GermanyRoby Thill: Association for Environmental Medicine (ALMEN)
Beaufort, Luxembourg
Igor Belyaev, Amy Dean, Horst Eger, Gerhard Hubmann, Reinhold Jandrisovits, Olle Johansson, Markus Kern, Michael Kundi, Piero Lercher, Wilhelm Mosgöller, Hanns Moshammer, Kurt Müller, Gerd Oberfeld*, Peter Ohnsorge, Peter Pelzmann, Claus Scheingraber and Roby ThillEUROPAEM EMF Guideline 2015 for the prevention, diagnosis and treatment of EMF-related health problems and illnesses
DOI 10.1515/reveh-2015-0033
Received October 1, 2015; accepted October 13, 2015
Abstract: Chronic diseases and illnesses associated
with unspecific symptoms are on the rise. In addition to
chronic stress in social and work environments, physi-
cal and chemical exposures at home, at work, and during
leisure activities are causal or contributing environmen-
tal stressors that deserve attention by the general practi-
tioner as well as by all other members of the health care
community. It seems certainly necessary now to take “new
exposures” like electromagnetic field (EMF) into account.
Physicians are increasingly confronted with health prob-
lems from unidentified causes. Studies, empirical obser-
vations, and patient reports clearly indicate interactions
between EMF exposure and health problems. Individual
susceptibility and environmental factors are frequently
neglected. New wireless technologies and applications
have been introduced without any certainty about their
health effects, raising new challenges for medicine and
society. For instance, the issue of so-called non-thermal
effects and potential long-term effects of low-dose expo-
sure were scarcely investigated prior to the introduction of
these technologies. Common EMF sources include Wi-Fi
access points, routers and clients, cordless and mobile
phones including their base stations, Bluetooth devices,
ELF magnetic fields from net currents, ELF electric fields
from electric lamps and wiring close to the bed and office
desk. On the one hand, there is strong evidence that long-
term-exposure to certain EMF exposures is a risk factor
for diseases such as certain cancers, Alzheimer’s disease
and male infertility. On the other hand, the emerging
electromagnetic hypersensitivity (EHS) is more and more
recognized by health authorities, disability administra-
tors and case workers, politicians, as well as courts of
law. We recommend treating EHS clinically as part of the
group of chronic multisystem illnesses (CMI) leading to
a functional impairment (EHS), but still recognizing that
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338      Belyaev et al.: EUROPAEM EMF Guideline 2015
the underlying cause remains the environment. In the
beginning, EHS symptoms often occur only occasionally,
but over time they may increase in frequency and severity.
Common EHS symptoms include headaches, concentra-
tion difficulties, sleeping problems, depression, lack of
energy, fatigue and flu-like symptoms. A comprehensive
medical history, which should include all symptoms and
their occurrences in spatial and temporal terms and in
the context of EMF exposures, is the key to the diagnosis.
The EMF exposure can be assessed by asking for typical
sources like Wi-Fi access points, routers and clients, cord-
less and mobile phones and measurements at home and
at work. It is very important to take the individual suscep-
tibility into account. The primary method of treatment
should mainly focus on the prevention or reduction of
EMF exposure, that is, reducing or eliminating all sources
of EMF at home and in the workplace. The reduction of
EMF exposure should also be extended to public spaces
such as schools, hospitals, public transport, and libraries
to enable persons with EHS an unhindered use (accessi-
bility measure). If a detrimental EMF exposure is reduced
sufficiently, the body has a chance to recover and EHS
symptoms will be reduced or even disappear. Many exam-
ples have shown that such measures can prove effective.
Also the survival rate of children with leukemia depends
on ELF magnetic field exposure at home. To increase the
effectiveness of the treatment, the broad range of other
environmental factors that contribute to the total body
burden should also be addressed. Anything that supports
a balanced homeostasis will increase a person’s resilience
against disease and thus against the adverse effects of EMF
exposure. There is increasing evidence that EMF exposure
has a major impact on the oxidative and nitrosative regu-
lation capacity in affected individuals. This concept also
may explain why the level of susceptibility to EMF can
change and why the number of symptoms reported in the
context of EMF exposures is so large. Based on our current
understanding, a treatment approach that minimizes the
adverse effects of peroxynitrite – as has been increasingly
used in the treatment of multisystem disorders – works
best. This EMF Guideline gives an overview of the current
knowledge regarding EMF-related health risks and pro-
vides concepts for the diagnosis and treatment and acces-
sibility measures of EHS to improve and restore individual
health outcomes as well as for the development of strate-
gies for prevention.
Keywords: accessability measures; alternating;
Alzheimer’s; cancer; chronic multisystem illnesses (CMI);
diagnosis; electric; electromagnetic field (EMF); electro-
magnetic hypersensitivity (EHS); functional impairment;
infertility; leukemia; magnetic; medical guideline; nitro-
sative stress; nonionizing; oxidative stress; peroxynitrite;
prevention; radiation; static; therapy; treatment.
Current state of the scientific and
political debate from a medical
perspective
Introduction
The Environmental Burden of Disease Project assessed
the influence of nine environmental stressors (benzene,
dioxins including furans and dioxin-like PCBs, second-
hand smoke, formaldehyde, lead, noise, ozone, particu-
late matter and radon) on the health of the population of
six countries (Belgium, Finland, France, Germany, Italy,
and the Netherlands). Those nine environmental stressors
caused 3%–7% of the annual burden of disease in the six
European countries (1).
The Bundespsychotherapeutenkammer (BPtK) study
in Germany showed that mental disorders had increased
further and especially burnout as a reason of inability
to work escalated seven-fold from 2004 to 2011 (2). In
Germany, 42% of early retirements in 2012 were caused by
mental disorders, depression being the leading diagnosis
(3). In Germany, psychotropic drugs are at third place for
the prescriptions of all drugs (4).
The consumption of methylphenidate (Ritalin,
Medikinet, Concerta), a psychotropic drug prescribed as
a treatment for attention deficit hyperactivity disorder
(ADHD) especially for young children and adolescents,
has increased alarmingly since the early 1990s. Accord-
ing to statistics of the German Federal Institute for Drugs
and Medical Devices (Bundesinstitut für Arzneimittel
und Medizinprodukte), prescriptions have increased
even more dramatically since 2000 and reached a climax
in 2012. In 2013, only a slight decline in the number of
prescriptions was observed (5). Interestingly the rapid
increase in the use of methylphenidate coincides with
the enormous expansion of mobile telecommunication
and other related technologies, posing an open research
question.
In Germany, work disability cases and absence days
due to mental health disorders more than doubled from
1994 to 2011 (6). In OECD countries, a huge variability
in the prescription of antidepressants has occurred and
generally an increasing trend has been observed. Socio-
economic status and therapeutic standards cannot fully
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Belyaev et al.: EUROPAEM EMF Guideline 2015      339
explain these observations (7). Functional disturbances
like chronic inflammation and changes of neurotransmit-
ter functions caused by environmental influences are not
investigated.
A steady increase in the prevalence of allergic/asth-
matic diseases globally has occurred, with about 30%–
40% of the world population now being affected by one or
more allergic/asthmatic conditions (8).
It is suspected that environmental conditions such
as the increasing exposure of the population to electro-
magnetic fields (EMFs) like radio-frequency radiation
(RF), emanating from e.g. cordless phones (DECT), mobile
phone base stations and cell phones (GSM, GPRS, UMTS,
LTE) – especially smartphones, data cards for laptop and
notebook computers, wireless LAN (Wi-Fi), wireless and
powerline communication-based smart meters, but also
exposure to extremely low frequency (ELF) electric and
magnetic fields including “dirty electricity”, emanating
from disturbances on the electric wiring, power lines, elec-
tric devices, and other equipment, do play a causal role
for EMF-related health effects (9–12). For the society and
the medical community, all of this raises new challenges.
Chronic diseases and illnesses associated with unspe-
cific symptoms are on the rise. In addition to chronic stress
in social and work environments, physical and chemical
exposures at home, at work, and during leisure activities
are causal or contributing environmental stressors that
deserve attention by the general practitioner as well as by
all other members of the health care community. It seems
certainly necessary now to take “new exposures” like EMF
into account.
Worldwide statements of organizations regarding EMF
The recommendations of the World Health Organization
(WHO) regarding extremely low frequency (ELF) electric
and magnetic fields and radio-frequency radiation, com-
piled by the International Commission on Non-Ionizing
Radiation Protection (ICNIRP) (13, 14), are based on induc-
tions of currents in the body and thermal effects (SAR
values). These recommendations were adopted by the EU
in its Council Recommendation of 1999 without taking into
account long-term nonthermal effects. However, it should
be stressed that at an international EMF conference in
London (2008), Professor Paolo Vecchia, head of ICNIRP,
said about the exposure guidelines “What they are not”:
“They are not mandatory prescriptions for safety”, “They
are not the ‘last word’ on the issue”, and “They are not
defensive walls for industry or others” (15).
Even for short-term effects, the application of
specific absorption rate (SAR) estimates seems to be not
appropriate (16).
In contrast to the WHO headquarter in Geneva, the
International Agency for Research on Cancer (IARC) , a
WHO-affiliated specialized agency in Lyon, classified
extremely low frequency magnetic fields as possibly car-
cinogenic to humans (Group 2B) in 2002 (17) and radio-
frequency radiation in 2011 (18).
In August 2007 and December 2012, the BioInitia-
tive Working Group, an international group of experts,
published comprehensive reports calling for preventive
measures against EMF exposure based on the available
scientific evidence (9, 10).
Since it is mostly neglected as a health hazard, the
European Environment Agency compared the risks of non-
ionizing radiation (EMF) to other environmental hazards
such as asbestos, benzene and tobacco, urgently recom-
mending to implement a precautionary approach regarding
EMF (19). This position was confirmed and elaborated more
deeply in further publications in 2011 and 2013 (20, 21).
In September 2008, a statement of the European
Parliament called for a review of the EMF limits set out
in the EU Council Recommendation of 1999, which was
based on the ICNIRP guidelines, with reference to the
BioInitiative Report (22). This was further strengthened in
the European Parliament resolution of April 2009 (23).
In November, 2009, a scientific panel met in Seletun,
Norway, for 3 days of intensive discussion on existing
scientific evidence and public health implications of the
unprecedented global exposures to artificial electromag-
netic fields. Such electromagnetic field exposures (static
to 300 GHz) result from the use of electric power and from
wireless telecommunications technologies for voice and
data transmission, energy, security, military and radar use
in weather and transportation.
At the meeting, the Seletun Scientific Panel adopted a
Consensus Agreement (24) that recommends preventative
and precautionary actions that are warranted now, given
the existing evidence for potential global health risks.
It recognizes the duty of governments and their health
agencies to educate and warn the public, to implement
measures balanced in favor of the Precautionary Princi-
ple (25), to monitor compliance with directives promoting
alternatives to wireless, and to fund research and policy
development geared toward prevention of exposures and
development of new public safety measures.
The Scientific Panel recognizes that the body of evi-
dence on electromagnetic fields requires a new approach
to protection of public health; the growth and develop-
ment of the fetus, and of children; and argues for strong
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340      Belyaev et al.: EUROPAEM EMF Guideline 2015
preventative actions. These conclusions are built upon
prior scientific and public health reports documenting the
following:
1) Low-intensity (non-thermal) bioeffects and adverse
health effects are demonstrated at levels significantly
below existing exposure standards.
2) ICNIRP and IEEE/FCC public safety limits are inad-
equate and obsolete with respect to prolonged, low-
intensity exposures.
3) New, biologically-based public exposure stand-
ards are urgently needed to protect public health
world-wide.
4) It is not in the public interest to wait.
The Panel also strongly recommends that persons with
electromagnetic hypersensitivity symptoms (EHS) be clas-
sified as functionally impaired in all countries rather than
with “idiopathic environmental disease” or similar indis-
tinct categories. This terminology will encourage govern-
ments to make adjustments in the living environment to
better address social and well-being needs of this subpop-
ulation of highly sensitive members of society, and – as
a consequence – protect everyone now as well as in the
coming generations from toxic environmental exposures.
It is important to note that numeric limits recom-
mended by the Seletun Scientific Panel, as well as by
other bodies of society, do not yet take into account sensi-
tive populations (EHS, immune-compromised, the fetus,
developing children, the elderly, people on medications,
etc.). Another safety margin is, thus, likely justified further
below the numeric limits for EMF exposure recommended
by the Panel.
In May 2011, the Parliamentary Assembly of the
Council of Europe adopted the report “The potential
dangers of electromagnetic fields and their effects on
the environment” (26). The Assembly recommended
many preventive measures for the member states of the
Council of Europe with the aim to protect humans and
the environment, especially from high-frequency electro-
magnetic fields such as: “Take all reasonable measures
to reduce exposure to electromagnetic fields, especially
to radiofrequencies from mobile phones, and particularly
the exposure of children and young people who seem
to be most at risk from head tumors” or “Pay particular
attention to “electrosensitive” people who suffer from a
syndrome of intolerance to electromagnetic fields and
introduce special measures to protect them, including
the creation of wave-free areas not covered by the wire-
less network.”
Recognizing that patients are being adversely
affected by EMF exposure, the American Academy of
Environmental Medicine published recommendations
regarding EMF exposure in July 2012. The AAEM called
for physicians to consider electromagnetic exposure in
diagnosis and treatment and recognize that EMF expo-
sure “may be an underlying cause of the patient’s disease
process” (27).
Since 2014 the Belgium government has prohibited
the advertising of cell phones for children under the age of
seven and has required the specific absorption rate (SAR)
of cell phones be listed. Furthermore, at the point of sale,
well-marked warnings must be posted that instruct users
to use headsets and to minimize their exposure (28).
In January 2015, the French parliament adopted a
comprehensive law that protects the general public from
excessive exposure to electromagnetic waves. Among
other things, it was passed to ban Wi-Fi in nurseries for
children under the age of three and to enable Wi-Fi at
primary schools with children under the age of 11 only
when used specifically for lessons. Public places offer-
ing Wi-Fi must clearly advertise this fact on a sign. At
the point of sale of cell phones, the SAR value must be
clearly shown. In the future, any cell phone advertise-
ment must include recommendations on how users can
reduce RF radiation exposure to the head such as the use
of headsets. Data on local EMF exposure levels shall be
made more easily accessible to the general public, among
others, through country-wide transmitter maps. Also, the
French government will have to submit a report on elec-
tromagnetic hypersensitivity to the parliament within a
year (29).
In May 2015 almost 200 scientists directed an interna-
tional appeal to United Nations (UN) and WHO and called
for protection from nonionizing electromagnetic field
exposure. In the appeal the scientifically proven effects
on health and the hitherto inadequate international
guidelines (ICNIRP) and their use by WHO had been
addressed. In addition, various demands were made in
nine points, such as that: “the public be fully informed
about the potential health risks from electromagnetic
energy and taught harm reduction strategies” and “that
medical professionals be educated about the biological
effects of electromagnetic energy and be provided train-
ing on treatment of patients with electromagnetic sensi-
tivity” (30).
Finally, in 2015 Pall (12) published a comprehen-
sive paper with the title “Scientific evidence contradicts
findings and assumptions of Canadian Safety Panel 6:
microwaves act through voltage-gated calcium channel
activation to induce biological impacts at non-thermal
levels, supporting a paradigm shift for microwave/lower
frequency electromagnetic field action”.
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EMF and cancer
Except for a few investigations in occupational settings,
epidemiological research of EMF started in 1979 when
Wertheimer and Leeper published their study about the
relationship between the proximity to so-called power
line poles with “service drop” wires and the occurrence of
childhood cancer (specifically leukemia and brain tumors)
(31). At the same time Robinette et al. studied mortality in
a cohort of Korean War veterans having been trained on
military radars in the early 1950s (32). Both studies found
indications of increased risks and initiated a new era of
studying health-relevant effects from exposure to EMFs.
In the following years, a large number of investiga-
tions about the relationship between childhood leuke-
mia and extremely low frequency magnetic fields (ELF
MF) have been published. However, the results seemed
inconsistent until in 2000 two pooled analyses (33, 34)
were conducted, providing little indication of inconsist-
ency and demonstrating an increase of leukemia risk with
increasing average exposure levels that was significant for
levels above 0.3 or 0.4 µT relative to averages below 0.1 µT
but without indication of a threshold. Based on these
findings, the International Agency for Research on Cancer
(IARC) classified ELF MF in 2002 as a Group 2B (possible)
carcinogen (17). To this category belong e.g. lead, DDT,
welding fumes, and carbon tetrachloride.
Since then additional epidemiological studies have
been conducted that gave essentially the same results (35,
36). In a review on childhood leukemia and ELF MF, Kundi
concluded that there is sufficient evidence from epidemio-
logical studies of an increased risk for childhood leuke-
mia from exposure to power-frequency MF that cannot
be attributed to chance, bias, or confounding. Therefore,
according to the rules of IARC, such exposures ought to be
classified as a Group 1 (definite) carcinogen (10).
The prognosis of certain diseases can be influenced
by EMF-reduction. For example, children who have leuke-
mia and are in recovery have poorer survival rates if their
ELF magnetic field exposure at home (or where they are
recovering) is between 1 mG [0.1 µT] and 2 mG [0.2 µT] or
above 2 mG [0.2 µT] in one study, over 3 mG [0.3 µT] in
another study (9).
Epidemiological studies of radio-frequency fields
before the general rise in exposure to mobile telecom-
munication networks was quite restricted and only a few
studies had been conducted in the vicinity of radio trans-
mitters, radar stations, other occupational exposures, a
in radio amateurs. After the introduction of digital mobile
telephony, the number of users of mobile phones increased
dramatically and it was recommended in the 1990s to
perform epidemiological studies with a focus on intrac-
ranial tumors. Since the first publication in 1999 by the
Swedish group around Prof. Lennart Hardell (37), about
40 studies have been published. The majority of these
studies investigated brain tumors, but also salivary gland
tumors, uveal melanoma, nerve sheath tumors, testicular
cancer, and lymphoma. Many of these studies are incon-
clusive because of too short exposure durations; however,
two series of investigations, the international Interphone
study conducted in 13 countries and the Swedish studies
of the Hardell group, had a significant proportion of long-
term mobile phone users and could in principle be used
for risk assessment. In 2011, IARC classified radio-fre-
quency electromagnetic fields (RF) as a Group 2B carcino-
gen based on evidence from epidemiological studies and
animal experiments (18). Since then, additional studies
have corroborated the assumption of a causal relationship
between mobile phone use and cancer (38–40). Hardell
and Carlberg (41) concluded that RF-EMF ought to be clas-
sified as a definitive human carcinogen (IARC Group 1).
The evidence for a causal relationship between long-term
mobile and cordless phone use and the risk for glioma has
increased further in 2015 (42).
In Italy, the Supreme Court upheld a ruling in October
2012 for an 80% disability rating and permanent disabil-
ity pension due to a tumor, which was causally connected
with the occupation-related heavy use of cell and cordless
phones (43).
EMF and neurodegeneration
Neurological effects are caused by changes in the nervous
system, including direct damage (neurodegeneration) to
nerve cells and their processes, the axons and dendrites, as
well as their terminal common functional entities, the syn-
apses with their receptors, ion channels and comodulators.
Factors that act directly or indirectly on the nervous system
causing morphological, chemical, and/or electrical changes
in the nervous system can lead to neurological alterations.
The final manifestation of these effects can be seen in neu-
rocognitive changes, e.g. memory, learning and perception,
as well as in primary sensory and motor incapacities.
The nervous system is an electrical organ based on a
very complex chemistry. Thus, it should not be surprising
that exposure to electromagnetic fields could lead to neu-
rodegeneration and concomitant or consecutive neuro-
logical changes. Morphological, chemical, electrical, and
behavioral changes have been reported in animals, cells
and tissues after exposure to electromagnetic fields across
a range of frequencies.
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The consequences of physiological changes in the
nervous system are very difficult to assess. We do not
fully understand how the nervous system functions and
reacts to external perturbations. The neuronal plastic-
ity of the nervous system could compensate for external
disturbances, at least to a certain degree. On the other
hand, the consequence of neural perturbation is also
situation-dependent. An EMF-induced severe change in
brain performance, for instance, could lead to different
consequences depending on whether a person is sitting in
a sofa watching TV or driving a car. The latter could very
well end dramatically, even fatally.
It should be noted that analyses of the recent neuro-
logical literature show that there are more publications
showing effects than no effects. So the question is not if
EMFs cause effects, but rather how serious they will be for
a given person.
Neurological effects of radio-frequency radiation (RFR)
There are many studies on human subjects. Many of the
published papers are on changes in brain electrical activi-
ties, the EEG, as well as impacts on sleep, after acute expo-
sure to cell phone radiation.
Bak et al. (44) reported effects on event-related
potentials. Maganioti et al. (45) further reported that RFR
affected the gender-specific components of event-related
potentials [see also Hountala et al. (46)]. Croft et al. (47)
reported changes of the alpha wave power in the EEG.
The same authors (48) further reported that effects dif-
fered between various new cell phone transmission
systems, which have different signaling characteristics.
They observed effects after exposure to second genera-
tion (2G), but not third generation (3G) radiation, whereas
Leung et al. (49) found similar EEG effects with both 2G
and 3G types of radiation. Lustenberger et al. (50) found
increased slow-wave activity in humans during exposure
to pulse-modulated RF EMF toward the end of the sleep
period. Vecchio and associates reported that cell phone
RFR affected EEG and the spread of neural synchroniza-
tion conveyed by interhemispherical functional coupling
of EEG rhythms (51) and enhanced human cortical neural
efficiency (52). An interesting finding is that RFR could
interact with the activity of brain epileptic foci in epilep-
tic patients (53, 54). However, no significant effect on EEG
was reported by Perentos et al. (55) or Trunk et al. (56).
And Kleinlogel et al. (57, 58) also reported no significant
effects on resting EEG and event-related potentials in
humans after exposure to cell phone RFR. Furthermore,
Krause et al. (59) reported no significant effect of cell
phone radiation on brain oscillatory activity, and Inomata-
Terada et al. (60) concluded that cell phone radiation does
not affect the electrical activity of the motor cortex.
There are studies on the interaction of cell phone
radiation on EEG during sleep. Changes in sleep EEG have
been reported by Hung et al. (61), Regel et al. (62), Lowden
et al. (63), Schmid et al. (64, 65), and Loughran et al. (66),
whereas no significant effect was reported by Fritzer et al.
(67), Mohler et al. (68, 69) and Nakatani-Enomoto et al.
(70). Loughran et al. (66) provided an interesting conclu-
sion in their paper: “These results confirm previous find-
ings of mobile phone-like emissions affecting the EEG
during non-REM sleep”. Importantly, this low-level effect
was also shown to be sensitive to individual variability. Fur-
thermore, this indicates that “previous negative results are
not strong evidence for a lack of an effect…” Increase in
REM sleep was reported by Pelletier et al. (71) in developing
rats after chronic exposure. Mohammed et al. (72) reported
a disturbance in REM sleep EEG in the rat after long term
exposure (1 h/day for 1 month) to a 900-MHz modulated
RFR. A Swiss Study revealed that, under pulse-modulated
radiofrequency electromagnetic field exposure, sleep slow-
wave activity is increased and – fitting to that – the sleep-
dependent performance improvement is decreased (50).
Among the very many effects reported in the ever
increasing number of scientific papers are also reduction
in behavioral arousal, sleep latency alterations, effects on
cognitive functions and EEG, on spatial working memory,
on well-being, influences on overall behavioral problems
in adolescents, alteration of thermal pain threshold and
visual discrimination threshold, respectively, induced
hyperactivity, hypoactivity and impaired memory, respec-
tively, contextual emotional behavior deficit, olfactory
and/or visual memory deficit, impact on food collection
behavior (in ants), decreased motor activity, learning
behavior deficit, induction of stress behavioral patterns,
passive avoidance deficit, and reduced memory functions.
Almost all the animal studies reported effects, whereas
more human studies reported no effects than effects. This
may be caused by several possible factors: (a) Humans are
less susceptible to the effects of RFR than are rodents and
other species. (b) Non-thermal effects of RFR depend on
a number of physical and biological parameters (73). The
same exposure can induce effects in certain biological
species while being ineffective in others. IARC also admits
that some of the discrepancies between RFR studies could
be due to differences in species [(18), p. 416]. (c) It may
be more difficult to do human than animal experiments,
since, in general, it is easier to control the variables and
confounding factors in an animal experiment. (d) In the
animal studies, the cumulative exposure duration was
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generally longer and studies were carried out after expo-
sure, whereas in the human studies, the exposure was
generally at one time and testing was done during expo-
sure. This raises the question of whether the effects of
RFR are cumulative. This consideration could have very
important implications on real-life human exposure to
EMF. However, it must be pointed out that neurophysi-
ological and behavioral changes have been reported in
both animals and humans after acute (one-time) exposure
to RFR, and most of the EEG studies mentioned above are
acute exposure experiments.
Neurological effects of extremely low frequency
electromagnetic fields (ELF-EMF)
A number of authors have reported effects of ELF-EMF on
various animal transmitter receptors in the brain such as
NMDA receptors, dopamine and serotonin receptors, includ-
ing the 5HT(2A) subtype of serotonin receptors. The latter
is classically, particularly in the frontal cortex, believed to
be related to the psychiatric syndromes of depression in
humans. Kitaoka et al. (74) and Szemerszky et al. (75) did
report depression-like behavior in both mice and rats, after
chronic exposure to ELF magnetic fields. There are two
reports on dopamine receptors. Shin et al. (76, 77) reported
an increase in D-1 dopamine receptors and activity in the
striatum of the rat after ELF magnetic field exposure. Dopa-
mine in the striatum is, of course, involved in Parkinson’s
disease. Wang et al. (78) reported that ELF magnetic fields
potentiated morphine-induced decrease in D-2 dopamine
receptors. Both D-1 and D-2 dopamine receptors in the brain
are involved in depression and drug addiction. Ravera et al.
(79) reported changes in the enzyme acetylcholinesterase
in cell membrane isolated from the cerebellum after ELF
magnetic field exposure. Interestingly, these researchers
also reported “frequency window” effects in their experi-
ment. Window effects, i.e. effects are observed at a certain
range(s) of EMF frequencies or intensities, were first
reported by Ross Adey, Susan Bawin, and Carl Blackman in
the 1980s. A study by Fournier et al. (80) reported an ‘inten-
sity window’ effect of ELF magnetic field on neurodevelop-
ment in the rat. The cholinergic systems in the brain play a
major role in learning and memory functions.
Behavioral effects of ELF-EMF have been further sub-
stantiated in recent research. These include: changes in
locomotor activity (76, 77, 81–86), learning and memory
functions (80, 87–95), anxiety (81, 93, 96–98), depression-
like behavior (74, 75), perception (99), cognitive dysfunc-
tion (100), emotional state (101), sleep onset (61), and
comb building in hornets (102). As different behavioral
effects have been observed in different exposure condi-
tions, species of animals, and testing paradigms, they
provide the strongest evidence that exposure to ELF-EMF
can affect the nervous system.
The possible medical applications of ELF-EMF should
also be given more attention. Several studies indicate
that ELF-EMF (however, mostly at high exposure levels)
could enhance recovery of functions after nervous system
damage and have protective effects against development
of neurodegenerative diseases. The majority of the studies
used magnetic fields above 0.1 mT (1 gauss; the highest
was 8 mT). The intensities are much higher than those in
the public environment. Thus, caution should be taken in
extrapolating the high-intensity cell and animal studies to
long-term environmental human exposure situations.
In addition, however, there are studies at low or very
low magnetic field exposure levels. Humans are sensi-
tive to magnetic fields at levels <1 µT. A study by Ross
et al. (99) showed “perception” alteration in human
subjects exposed to a magnetic field at 10 nT (0.00001
mT), a study by Fournier et al. (80) showed an effect on
brain development in the rat at 30 nT (0.00003 mT), and
a study by Stevens (101) indicated changes in emotional
states in humans exposed to 8–12 Hz magnetic fields at 5
µT (0.005 mT). These data do suggest magnetic fields at
very low intensities could cause neurological effects in
humans. In the 1990s, there was a series of more than 20
studies published by Reuven Sandyk, showing that pulsed
magnetic fields at picotesla levels (1 pT = 0.000000001 mT)
could have therapeutic effects on Parkinson’s disease and
multiple sclerosis [see e.g. (103)]. However, Sandyk’s find-
ings have never been independently confirmed.
The above mentioned therapeutic applications of EMF
elicit that different EMF-exposures have biological effects
under certain conditions for short-term use.
Alzheimer’s disease
Amyloid beta (Aβ) protein is generally considered the
primary neurotoxic agent causally associated with Alzhei-
mer’s disease. Aβ is produced by both brain and periph-
eral cells and can pass through the blood brain barrier.
The BioInitiative review 2012 (10) summarized the evi-
dence concerning Alzheimer’s disease as follows:
1) There is longitudinal epidemiologic evidence that
high peripheral blood levels of Aβ, particularly Aβ1-
42, are a risk factor for Alzheimer’s disease.
2) There is epidemiologic evidence that extremely low
frequency (ELF, 50–60 Hz) magnetic field (MF) expo-
sure upregulates peripheral blood levels of Aβ.
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3) There is evidence that melatonin can inhibit the
development of Alzheimer’s disease and, thus, low
melatonin levels may increase the risk of Alzheimer’s
disease.
4) There is strong epidemiologic evidence that signifi-
cant (i.e. high), occupational ELF-MF exposure can
lead to the downregulation of melatonin production.
The precise components of the magnetic fields caus-
ing this downregulation are unknown. Other factors
which may influence the relationship between ELF-
MF exposure and melatonin production are unknown,
but certain medications may play a role.
5) There is strong epidemiologic evidence that high
occupational ELF MF exposure is a risk factor for
Alzheimer’s disease, based on case-control studies
which used expert diagnoses and a restrictive classifi-
cation of ELFMF exposure.
6) There are only single epidemiologic studies of Alzhei-
mer’s disease and radio-frequency electromagnetic
field exposure, and only one epidemiology study
of non-acute radio-frequency electromagnetic field
exposure and melatonin. So, no final conclusions
concerning health consequences due to RF exposure
and Alzheimer’s disease are currently possible.
Hallberg and Johansson (104) demonstrated that the mor-
tality in Alzheimer’s disease appears to be associated
with mobile phone output power. Deeper studies in this
complex area are still necessary.
There is epidemiological evidence that also residen-
tial exposure to ELF magnetic fields is associated with an
increased risk for Alzheimer’s disease (105, 106).
Earlier reviews of the association between exposure to
ELF MF and neurodegenerative diseases came to different
conclusions (107, 108). The discrepancy is mainly due to two
aspects: the assessment of a possible publication bias and
the selection and classification of exposed groups. Since
most studies are about occupational exposure, it is manda-
tory to avoid misclassification. If care is taken to avoid such
ambiguity, there is a clear meta-analytical relationship and
an increased risk for Alzheimer’s disease and amyotrophic
lateral sclerosis (ALS). This association shows little het-
erogeneity across studies if the different methodologies
are considered and publication bias has been detected for
studies relying on mortality registries only (109).
EMF and infertility and reproduction
Infertility and reproduction disorders are on the rise. The
BioInitiative review 2012 (10) summarized the evidence
concerning infertility and reproduction as follows – with
small adaptations by the authors:
Human sperm are damaged by cell phone radiation at
very low intensities, in the low microwatt and nanowatt
per cm2 range (0.00034–0.07 µW/cm2 = 3.4–700 µW/m2).
There is a veritable flood of new studies reporting sperm
damage in humans and animals, leading to substantial
concerns for fertility, reproduction, and health of the off-
spring (unrepaired de novo mutations in sperm). Expo-
sure levels are similar to those resulting from wearing a
cell phone on the belt or in a pants pocket, or from using
a wireless laptop computer on the lap. Sperm lack the
ability to repair DNA damage.
Several international laboratories have replicated
studies showing adverse effects on sperm quality, motil-
ity, and pathology in men who use cell phones and partic-
ularly those who wear a cell phone, PDA, or pager on their
belt or in a pocket (110–115). Other studies conclude that
the use of cell phones, exposure to cell phone radiation, or
storage of a cell phone close to the testes of human males
affect the sperm count, motility, viability, and structure
(110, 116, 117). Animal studies have demonstrated oxida-
tive and DNA damage, pathological changes in the testes
of animals, decreased sperm mobility and viability, and
other measures of deleterious damage to the male germ
line (118–122).
There are fewer animal studies that have studied
effects of cell phone radiation on female fertility para-
meters. Panagopoulos (123) report decreased ovarian
development and size of ovaries, and premature cell death
of ovarian follicles and nurse cells in Drosophila mela-
nogaster. Gul et al. (124) report rats exposed to standby
level RFR (phones on but not transmitting calls) caused
decrease in the number of ovarian follicles in pups born
to these exposed dams. Magras and Xenos (125) reported
irreversible infertility in mice after five (5) generations of
exposure to RFR at cell phone tower exposure levels of
less than one microwatt per centimeter squared ( < 1 µW/
cm2 =  < 10 mW/m2).
Electromagnetic hypersensitivity (EHS)
An increasing number of human beings are continuously
exposed in their daily life to increasing levels of a com-
bination of static, ELF and VLF electric and magnetic
fields and RF electromagnetic fields. These exposures
are of different signal patterns, intensities, and techni-
cal applications for varying periods of time. All these
fields are summarized as EMF, colloquially referred to as
“electrosmog”.
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In a questionnaire survey in Switzerland in 2001,
which was addressed to persons attributing specific
health problems to EMF exposure, of the 394 respondents
58% suffered from sleep problems or disorders, 41% from
headaches, 19% from nervousness, 18% from fatigue and
16% from difficulties with concentration. The respondents
attributed their symptoms, e.g. to mobile phone base sta-
tions (74%), cell phones (36%), cordless phones (29%),
and high-voltage power lines (27%). Two thirds of the
respondents had taken measures to reduce their symp-
toms, the most frequent one being to avoid exposure (126).
In a survey conducted 2009 in a Japanese EHS and
multiple chemical sensitivity (MCS) self-help group (n = 75),
45% of the respondents had EHS as a medical diagnosis,
49% considered themselves EHS. Every second responder
had medically diagnosed MCS (49%) and self-diagnosed
MCS had 27%. The main EHS-related symptoms were
fatigue (85%), headache (81%), concentration problems
(81%), sleeping disorders (76%) and dizziness (64%). The
most frequent causes include: base stations (71%), other
persons mobile phones (64%), PC (63%), power lines
(60%), television (56%), own mobile phone (56%), public
transportation (55%) , cordless phones (52%), air condi-
tioner (49%) and car (49%). Suspected EMF source of EHS
onset were: mobile phone base stations (37%), PC (20%),
electric home appliances (15%), medical equipment (15%),
mobile phones (8%), power lines (7%) and induction
cookers (7 %) (127).
In 2001, 63 persons who attributed health prob-
lems to environmental exposure were counseled in an
interdisciplinary environmental medicine pilot project
in Basel. An interdisciplinary expert team assessed the
individual symptoms by a medical psychological-psychi-
atric and environmental examination, including visits
and environmental measurements at home. With respect
to the 25 persons with EHS, the expert team attested that
in one third of them, at least one symptom was plausi-
bly related to electrosmog, although the EMF exposure
was within the Swiss limits. They concluded that persons
with EHS should be advised interdisciplinary, not only
medically and psychologically but also environmentally
(128, 129).
A representative telephone survey (n = 2048; age  > 14
years) carried out in 2004 in Switzerland yielded a fre-
quency of 5% (95% CI 4%–6%) for having symptoms
attributed to electrosmog, so-called electromagnetic
hypersensitivity. Remarkably, only 13% consulted their
family doctor. Individuals with a past history of symp-
toms attributable to EMF gave “turned off the source” as
the answer three times as often as the ones who still had
symptoms (130).
In a Swiss questionnaire study of GPs in 2005, two-
thirds of the doctors were consulted at least once a year
because of symptoms attributed to EMF. Fifty-four percent
of the doctors assessed a relation as possible. The doctors
in this questionnaire asked for more general information
about EMF and health and instructions on how to deal
with persons with EHS (131).
In another questionnaire study, also mandated by the
Swiss Federal Government and performed by the Univer-
sity of Bern in 2004, Swiss doctors working with comple-
mentary diagnostic and therapeutic tools reported that
71% of their consultations related to EMF. Remarkably,
not only the patients, but even more so the doctors sus-
pected a possible relation between illness and EMF. The
reduction or elimination of environmental sources was
the main therapeutic instrument in treating symptoms
related to EMF (132).
A questionnaire study of Austrian doctors yielded
similar results. In this study, the discrepancy between the
physicians’ opinions and established national and inter-
national health risk assessments was remarkable, consid-
ering that 96% of the physicians believed to some degree
in or were totally convinced of a health-relevant role of
environmental electromagnetic fields (133).
The question, whether EHS is causally associated
with EMF exposure remains controversial. On the one
hand, physicians judge a causal association between EMF
exposures as plausible based on case reports, on the other
hand, national and international health risk assessments
mostly claim that there is no such causal association,
because provocation studies under controlled blinded
conditions mostly failed to show effects. However, all
these studies used a very limited number of exposure con-
ditions, the exposure duration and the examined effects
were short, and the recruitment of the persons with EHS
was not medically assessed.
The WHO, for example, does not consider EHS as a
diagnosis and recommends to medical doctors that the
treatment of affected individuals should focus on the
health symptoms and the clinical picture, and not on a
person’s perceived need for reducing or eliminating EMF
in the workplace or home (134).
The evaluation report about electromagnetic hyper-
sensitivity mandated by the Swiss federal government
assessed the evidence of a causal relationship between
EMF exposure and biological and health effects. It took
into account not only experimental, observational studies
and meta-analyses, but also individual experiments and
case reports. For the evaluation of the scientific evidence,
the GRADE criteria were applied. Individual case reports
were considered to be of great importance because it is
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likely that, at the same exposure level, not all people react
the same as rare cases may be misunderstood by otherwise
statistically reliable scientific methods of investigation,
and since habituation and sensitization processes of a
person’s reaction can change during the time of exposure.
The significance of case reports with regard to scientific
evidence based on the strict GRADE criteria used in this
evaluation, however, was considered to be limited, mainly
because of the distortion due to methodological flaws. It
was noted in the report that individual case experiments
with repeated testing of an EHS person under double-
blind conditions and controlled exposure would be more
revealing than experimental studies with larger groups.
Ideally, a test of the person concerned should be carried
out in their familiar surroundings (e.g. at home) with a
reliable and accurate measurement of exposure. With pos-
itive test results, a re-evaluation would be required also
from a scientific perspective (135).
The paper “Electromagnetic hypersensitivity: fact
or fiction” by Genius and Lipp (136) offers an instructive
review of studies of the last decades concerning EHS,
including historical milestones, reviews, pathogenesis,
biochemical markers, therapeutic management, as well
as the debate about the legitimacy of EHS.
In Sweden, EHS is an officially fully recognized func-
tional impairment (i.e. it is not regarded as a disease).
Survey studies show that somewhere between 230,000
and 290,000 Swedish men and women out of a population
of 9,000,000 – report a variety of symptoms when being in
contact with EMF sources. With reference to UN Resolution
48/96, Annex, of 20 December 1993, the Swedish govern-
ment grants support to individuals with EHS. Employees
with EHS have a right to support from their employers so
as to enable them to work despite this impairment. Some
hospitals in Sweden provide rooms with low-EMF expo-
sure (137).
In Sweden, impairments are viewed from the point of
the environment. No human being is in itself impaired;
there are instead shortcomings in the environment that
cause the impairment (as with the lack of ramps for
the person in a wheelchair or rooms requiring low-EMF
remediation for the person with EHS). Furthermore, this
environment-related perspective of the impairment EHS
means that – even though we do not have a complete
scientific explanation, and, in contrast, to what many
individuals involved in the EMF discourse at present
think – any person with EHS shall always be met in a
respectful way and with all necessary support required
to eliminate the impairment. This implies that the person
with EHS shall have the opportunity to live and work in a
low-EMF environment (138).
In Sweden, the City of Stockholm offers low-EMF
housing on its outskirts to electrosensitive individuals.
In France, the first low-EMF zone has been established
at Drôme in July 2009 (139). In Austria, the construction
of a multi-family house has been planned for 2015, which
was designed by a team of architects, building biology
professionals, and environmental medicine health care
professionals to provide a sustainable healthy living envi-
ronment. Both the outdoor and indoor environments were
explicitly chosen and designed to meet low-EMF require-
ments (140). The implementation of low-EMF zones for
electrosensitive individuals is pursued in numerous coun-
tries. The realization of such projects greatly depends
on the understanding, knowledge, and tolerance of the
members of the chosen community.
In a human provocation study, Johansson (141), using a
controlled, double-blind pilot setup, found one EHS person
that correctly identified the presence of a mobile phone
nine times out of nine provocations (p < 0.002), both in the
“acute” phase as well as in the “chronic” phase (p < 0.001).
In facial skin samples of electrohypersensitive persons,
the most common finding has been a profound increase of
mast cells (142). From this and other studies, it is clear that
the number of mast cells in the upper dermis is increased in
the EHS group. A different pattern of mast cell distribution
also occurred in the EHS group. Finally, in the EHS group,
the cytoplasmic granules were more densely distributed
and more strongly stained than in the control group, and
the size of the infiltrating mast cells was generally found to
be larger in the EHS group as well. It should be noted that
increases of similar nature later on were demonstrated in
an experimental situation, employing normal healthy vol-
unteers in front of cathode ray tube (CRT) monitors, includ-
ing ordinary household television sets (143).
In one of the early papers, Johansson et al. (144)
made a sensational finding when they exposed two elec-
trically sensitive individuals to a TV monitor situated at
a distance of 40–50 cm away from them. The scientists
used an open-field provocation in front of an ordinary TV
set with persons regarding themselves as suffering from
skin problems due to work at video display terminals.
Employing fluorescence microscopy-based immunohisto-
chemistry, in combination with a wide range of antisera
directed towards cellular and neurochemical markers,
they were able to show a high to very high number of
somatostatin-immunoreactive dendritic cells as well as
histamine-positive mast cells in skin biopsies from the
anterior neck taken before the start of the provocation. At
the end of the provocation, however the number of mast
cells was unchanged and the somatostatin-positive cells
had seemingly disappeared. The reason for this latter
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finding could be discussed in terms of loss of immunore-
activity, increase of breakdown, etc. The high number of
mast cells present may explain the clinical symptoms of
itch, pain, edema, and erythema.
Against this background, it is interesting to see that
the early Swedish findings from the 1980s and 1990s are
supported by the latest work of Belpomme and Irigaray
(145). Since 2009, Belpomme and Irigaray prospectively
investigated clinically and biologically 1200 consecu-
tive EHS and/or MCS-self reported cases in an attempt to
establish objective diagnosis criteria and to elucidate the
pathophysiological aspects of these two disorders.
In their preliminary results, as presented at the Fifth
Paris Appeal Congress in Belgium in 2015 – based on the
analysis of 839 originally enrolled cases of which 810 met
the inclusion criteria and 727 were evaluable – 521 were
diagnosed with EHS, 52 with MCS, and 154 with both
EHS and MCS. Concomitant multiple food intolerance
was found in 28.5%, 41.9%, and 70.4% of the cases in the
three groups, respectively. Histamine levels were ana-
lyzed in the blood of patients, and 37%, 36.7% and 41.5%
of the persons respectively in the three above individual-
ized groups showed a significant increase in histamine-
mia ( > 10 nmol/L), meaning that a chronic inflammatory
response can be detected in these patients.
They also measured nitrotyrosin (NTT), a marker
of both peroxynitrite (ONOO.-) production and opening
of the blood brain barrier (BBB). NTT was increased in
the blood ( > 0.90 µg/mL) in 29.7%, 26%, and 28% of the
cases in the three groups, respectively. Likewise protein
S100B, another marker of BBB opening was found to be
increased in the blood ( > 0.105 µg/L) in 14.7%, 19.7%, and
10.7% of their cases, respectively. Circulating antibodies
against O-myelin, heat shock protein (Hsp) 27, and/or Hsp
70 protein were also found to be increased in 43.1%, 25%,
and 52% of their cases, respectively, indicating that EHS
and MCS are associated with some autoimmune response.
Since most patients reported chronic insomnia and
fatigue, they also determined the 24-h urine melatonin/
creatinine ratio and found it was decreased ( < 0.8) in all
investigated cases.
Finally, in order to gain further information about the
underlying mechanisms of EHS and MCS, they serially
measured the brain blood flow in the temporal lobes of each
patient by using pulsed brain echodoppler. They found
that both EHS and MCS were associated with a hypop-
erfusion in the capsulo-thalamic area of the brain, sug-
gesting that the inflammatory process may in fact involve
the limbic system and the thalamus. Both EHS and MCS
thus appear to paint a common picture of inflammation-
related hyper-histaminemia, oxidative stress, autoimmune
response, and BBB opening, and a deficit in melatonin
excretion. According to Belpomme and Irigaray, EHS and
MCS probably share a common pathological mechanism
mainly involving the central nervous system (145).
While a 2006 study by Regel et al. (146) described no
exposure effects, two provocation studies on exposure
of “electrosensitive” individuals and control subjects to
mobile phone base station signals (GSM, UMTS or both)
found a significant decline in well-being after UMTS expo-
sure in the individuals reporting sensitivity (147, 148). Most
so-called provocation studies with EHS show no effects.
However, all these studies used a very limited number
of exposure conditions. Taking in account the strong
dependence of EMF effects on a variety of physical and
biological variables (73), available provocation studies are
scientifically difficult to interpret and, in fact, are not suit-
able to disprove causality.
There is increasing evidence in the scientific literature
of various subjective and objective physiological altera-
tions, e.g. heart-rate variability (HRV) as apparent in some
persons with EHS claiming to suffer after exposure to
certain frequencies of EMR like DECT or Wi-Fi (149–153).
Analysis of the data available on the exposure of
people living near mobile phone base stations has yielded
clear indications of adverse health effects like fatigue,
depression, difficulty in concentrating, headaches, dizzi-
ness, etc. (154–158).
The frequency spectrum between ELF and RF is
referred as kHz range or intermediate frequency range.
Residential exposures in this range are often due to “dirty
power”/ “dirty electricity” originating from voltage and/or
current perturbations from diverse sources like electronic
power supplies for TVs, monitors, PCs, motor drives,
inverters, dimmers, CFLs, phase-angle control devices,
as well as sparking and arcing from switching operations
and from electric motors with brushes. The kHz waves/
transients travel along the electric wiring and grounding
systems (conducted emissions) and radiate electric and/
or magnetic fields into free space (radiated emissions),
leading to human exposures in the vicinity.
Epidemiological evidence links dirty electricity to
most of the diseases of civilization including cancer,
cardiovascular disease, diabetes, suicide, and attention
deficit hyperactivity disorder in humans (159).
When it comes to health effects of static magnetic
fields, this type of EMF exposure is frequently underesti-
mated. Blackman reports in the 2007 BioInitiative Report
(9): “The magnetic field of the earth at any given location
has a relatively constant intensity as a function of time.
However, the intensity value, and the inclination of the
field with respect to the gravity vector, varies considerable
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over the face of the earth. More locally, these features of
the earth’s magnetic field can also vary by more than 20%
inside man-made structures, particularly those with steel
support structures. There are many reports of EMF-caused
effects being dependent on the static magnetic field
intensity (cf. Blackman et al., 1985) and of its orientation,
with respect to an oscillating magnetic field (Blackman
et al., 1990; Blackman et al., 1996). One aspect common
to many of these reports is that the location in the active
frequency band is determined by the intensity of the
static magnetic field. There have been many attempts to
explain this phenomenon but none has been universally
accepted. However, it is clear that if a biological response
depends on the static magnetic field intensity, and even
its orientation with respect to an oscillating field, then the
conditions necessary to reproduce the phenomenon are
very specific and might easily escape detection (cf. Black-
man and Most, 1993). The consequences of these results
are that there may be exposure situations that are truly
detrimental (or beneficial) to organisms but that are insuf-
ficiently common on a large scale that they would not
be observed in epidemiological studies; they need to be
studied under controlled laboratory conditions to deter-
mine impact on health and wellbeing”.
On July 8, 2015, a court in Toulouse, France, ruled in
favor of a woman with the diagnosis “syndrome of hyper-
sensitivity to electromagnetic radiation” and determined
her disability to be 85% with substantial and lasting
restrictions on access to employment (160).
Possible mechanism of EHS
Based on the scientific literature on interactions of EMF
with biological systems, several mechanisms of interac-
tion are possible. A plausible mechanism at the intracel-
lular and intercellular level, for instance, is an interaction
via the formation of free radicals or oxidative and nitrosa-
tive stress (161–169). A review by Pall (12, 170, 171) provides
substantial evidence for a direct interaction between static
and time varying electric fields, static and time varying
magnetic fields and electromagnetic radiation with volt-
age-gated calcium channels (VGCCs). The increased intra-
cellular Ca2+ produced by such VGCC activation may lead
to multiple regulatory responses, including increased
nitric oxide levels produced through the action of the
two Ca2+/calmodulin-dependent nitric oxide synthases,
nNOS and eNOS. In most pathophysiological contexts,
nitric oxide reacts with superoxide to form peroxynitrite,
a potent nonradical oxidant, which can produce radical
products, including hydroxyl and NO2 radicals.
Peroxynitrite is by far the most damaging molecule in
our body. Although not a free radical in nature, peroxyni-
trite is much more reactive than its parent molecules NO
and O2-. The half-life of peroxynitrite is short (10–20 ms),
but sufficiently long to cross biological membranes,
diffuse one to two cell diameters, and allow significant
interactions with most critical biomolecules and struc-
tures (cell membranes, nucleus DNA, mitochondrial DNA,
cell organelles), and a large number of essential metabolic
processes (165). Elevated nitrogen monoxide, formation
of peroxynitrite, and induction of oxidative stress can be
associated with chronic inflammation, damage of mito-
chondrial function and structure, as well as loss of energy,
e.g. via the reduction of adenosine triphosphate (ATP).
The importance of ATP has been shown for CFS (172)
and for stress control (173). Those patients describe the
same symptoms as those suffering from CMI. This could
indicate similarities in the pathomechanisms. Similar
disturbances in neurotransmitter expression had been
described both with chronic exposure to EMF (174) and in
CMI patients (163, 175).
Redmayne and Johansson (176) published a review
considering the evidence for an association between
myelin integrity and exposure to low-intensity radiofre-
quency electromagnetic fields (RF-EMFs) typical in the
modern world, pointing to that RF-EMF-exposed animals/
humans show: 1) significant morphological lesions in the
myelin sheath of rats; 2) a greater risk of multiple sclerosis
in a study subgroup; 3) effects in proteins related to myelin
production; and 4) physical symptoms in individuals with
the functional impairment electrohypersensitivity, many
of which are the same as if myelin were affected by RF-EMF
exposure, giving rise to symptoms of demyelination. In the
latter, there are exceptions; headache is common only in
electrohypersensitivity, while ataxia is typical of demyeli-
nation but infrequently found in the former group. Overall,
evidence from in vivo and in vitro and epidemiological
studies suggests an association between RF-EMF exposure
and either myelin deterioration or a direct impact on neu-
ronal conduction, which may account for many electrohy-
persensitivity symptoms. The most vulnerable are likely to
be those in utero through to at least mid-teen years, as well
as ill and elderly individuals.
Complaints in chronic fatigue syndrome (CFS),
fibromyalgia (FM), multiple chemical sensitivity (MCS),
posttraumatic stress disorder (PTSD) and Gulf War syn-
drome (GWS) are almost the same. But the cardinal symp-
toms are different. Meanwhile, they are summarized as
chronic multisystem illnesses (CMI) (175). In all of them,
various disturbances of functional cycles have been
shown as activation of nitrogen oxide and peroxynitrite,
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chronic inflammation by activation of NF-kB, IFN-y, IL-1,
IL-6, and interaction with neurotransmitter expression
(163, 175, 177). We recommend classifying EHS as part of
CMI (170, 178) leading to a functional impairment (EHS),
but still recognizing that the underlying cause remains
only the environment (see Figure 1).
Other diseases that require attention with respect to EMF
There is some evidence that transient electromagnetic
fields (dirty electricity), in the kilohertz range on electrical
wiring, may be contributing to elevated blood sugar levels
among diabetics and pre-diabetics. In an electromagneti-
cally clean environment, Type 1 diabetics required less
insulin and Type 2 diabetics had lower levels of plasma
glucose. Dirty electricity, generated by electronic equip-
ment and wireless devices, is ubiquitous in the environ-
ment. Exercise on a treadmill, which produced dirty
electricity, increased plasma glucose. These findings may
explain why brittle diabetics have difficulty regulating
blood sugar. Based on estimates of people who suffer from
symptoms of electrohypersensitivity (3%–35%), as many
as 5–60 million diabetics worldwide may be affected (179).
The Bioinitiative Report 2012 (10) concluded: Fetal
(in-utero) and early childhood exposures to cell phone
radiation and wireless technologies in general may be a
risk factor for hyperactivity, learning disorders and behav-
ioral problems in school. Common sense measures to
limit both ELF-EMF and RF EMF in these populations is
needed, especially with respect to avoidable exposures
like incubators that can be modified; and where educa-
tion of the pregnant mother with respect to laptop com-
puters, mobile phones and other sources of ELF-EMF and
RF EMF are easily instituted.
This section deserves special attention in order to
respond timely to the rapid technological development
leading to more and more complex EMF exposures.
Recommendations for action
EUROPAEM has developed guidelines for differential
diagnosis and potential treatment of EMF-related health
problems with the aim to improve/restore individual
health outcomes and to propose strategies for prevention.
Evidence of treatment strategies for EMF-related illness including EHS
There are only a few studies assessing evidence-based
therapeutic approaches to EHS. The interdisciplinary
based assessing and counseling of EHS in the Swiss envi-
ronmental pilot project performed in 2001 showed in an
evaluation interview half a year after counseling, that 45%
of persons with EHS had benefitted from realizing certain
advice, for example, changing the bedroom (128, 129).
In the 2005 Swiss questionnaire study of physi-
cians working with complementary therapeutic tools,
two-thirds chose exposure reduction as a principal tool,
Figure 1: Pathogenesis of inflammation, mitochondriopathy, and nitrosative stress as a result of the exposure to trigger factors (177).
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Bacteria
Viruses
Industrial pollutants
Nitrosative Stress
/ Nitric i°Kide "
Superoxid t Peroxynitrite t iNOS t
l " Mitochondriopathy
ATP j ~ Oxidative Stress /
Solvents
EMF
Plastizisers
Food
Severe psycho-social Stress
Impaired
Inflammation -Immune -Tolerance
TNF-o.
lnterferon-y
Histamine
TH2 dominance
Loss of
T,09 cells
350      Belyaev et al.: EUROPAEM EMF Guideline 2015
whereas complementary therapeutics were only chosen
as a supplement (132).
Since 2008, the Swiss Society of Doctors for the Envi-
ronment has run a small interdisciplinary environmen-
tal medicine counseling structure for persons with EHS,
which is embedded in everyday practice with a central
coordination and consultation office as well as a network
of general practitioners interested in environmental medi-
cine who perform environmental medical assessments
and consultations based on a standard protocol. If nec-
essary, environmental experts are consulted and home
inspections are conducted. The aim of the assessments is
to detect or rule out common diseases and to analyze the
impact of suspected environmental burdens on the com-
plaints in order to find individual therapeutic approaches.
The main instrument of the assessment is an extensive
medical and psycho-social history with an additional
environmental history, including a systematic question-
naire and environmental key questions.
In the first years, the project was scientifically
assessed. In a questionnaire one year after counseling,
70% of the persons recommended the interdisciplinary-
based counseling structure and 32% of them considered
the counseling as being helpful. Therefore, a model based
on such an interdisciplinary concept, embedded in the
family doctor’s holistic and lasting concept of treatment,
seems to be promising for a better therapeutic approach to
EHS, also including accessibility measures targeted at the
actual environment (180).
In Finland, psychotherapy is the officially recom-
mended therapy of EHS. In a questionnaire study of EHS
people in Finland, symptoms, perceived sources and
treatments, the perceived efficacy of medical and comple-
mentary alternative treatments (CAM) in regards to EHS
were evaluated by multiple choice questions. According to
76% of the 157 respondents, the reduction or avoidance of
EMF helped in their full or partial recovery. The best treat-
ments for EHS were given as weighted effects: “dietary
change” (69.4%), “nutritional supplements” (67.8%), and
“increased physical exercise” (61.6%). The official treat-
ment recommendations of psychotherapy (2.6%) were
not significantly helpful, or for medication (–4.2%) even
detrimental. The avoidance of electromagnetic radiation
and fields effectively removed or lessened the symptoms
in persons with EHS (181, 182).
The prognosis of certain diseases can be influenced by
EMF-reduction. For example, children who have leukemia
and are in recovery have poorer survival rates if their ELF
magnetic field exposure at home (or where they are recover-
ing) is between 1 mG [0.1 µT] and 2 mG [0.2 µT] or above 2 mG
[0.2 µT] in one study, over 3 mG [0.3 µT] in another study (9).
Response of physicians to this development
In cases of unspecific health problems (see Questionnaire)
for which no clearly identifiable cause can be found –
beside other factors like chemicals, nonphysiological
metals, mold – EMF exposure should, in principle, be
taken into consideration as a potential cause or cofactor,
especially if the person presumes it.
A central approach for a causal attribution of symp-
toms is the assessment of variation in health problems
depending on time and location and individual suscep-
tibility, which is particularly relevant for environmental
causes such as EMF exposure.
Regarding such disorders as male infertility, mis-
carriage, Alzheimer’s, ALS, blood sugar fluctuations,
diabetes, cancer, hyperactivity, learning disorders and
behavioral problems in school, it would be important to
consider a possible link with EMF exposure. This offers
an opportunity to causally influence the course of the
disease.
How to proceed if EMF-related health problems are suspected
The recommended approach to diagnosis and treatment
is intended as an aid and should, of course, be modified
to meet the needs of each individual case (see Figure 2).
1. History of health problems and EMF exposure
2. Examination and findings
3. Measurement of EMF exposure
4. Prevention or reduction of EMF exposure
5. Diagnosis
6. Treatment
History of health problems and EMF exposure
In order to put later findings into a larger context, a
general medical history is necessary. In the next steps, we
focus only on EMF-related health effects.
A questionnaire to take a systematic history of health
problems and EMF exposure, compiled by the EUROPAEM
EMF Working Group, is available in the Annex of this EMF
Guideline.
The questionnaire consists of three sections:
a) List of symptoms
b) Variation of health problems depending on time,
location, and circumstances
c) Assessment of certain EMF exposures that can be esti-
mated by questionnaire
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Belyaev et al.: EUROPAEM EMF Guideline 2015      351
List of symptoms
The list of symptoms in the questionnaire serves to
systematically quantify health problems regardless of
their causes. It also includes questions as to when the
health problems first occurred. Most EMF-related symp-
toms are nonspecific and fall within the scope of health
problems due to inadequate regulation (decompensa-
tion), e.g. sleep problems, fatigue, exhaustion, lack of
energy, restlessness, heart palpitations, blood pressure
problems, muscle and joint pain, headaches, increased
risk for infections, depression, difficulty concentrating,
disturbances of coordination, forgetfulness, anxiety,
urinary urgency, anomia (difficulty finding words), diz-
ziness, tinnitus, and sensations of pressure in the head
and ears.
The health problems may range in severity from
benign, temporary symptoms, such as slight headaches or
paresthesia around the ear, e.g. when using a cell phone,
or flu-like symptoms after maybe some hours of whole
body EMF exposure, to severe, debilitating symptoms
that drastically impair physical and mental health. It has
to be stressed that, depending on the individual state of
Take special medical history, including the assessment of symptoms, diseases, and
circumstances regarding the times and places of appearance of symptoms
(see Annex Patient Questionnaire)
Differential diagnosis including
diagnostic tests Assessment of EMF exposure
Reduction and prevention of
EMF exposure
EMF exposure presented by the patient / person
or
EMF exposure suspected by the physician
Relevance and conclusion
Possible association
with EMF
Association with other
environmental factors
Reduction and
prevention of other
environmental factors
No relevant association
with environmental factors
Consultation of other
disciplines
Medical treatment
Figure 2: Flowchart for the handling of EMF-related health problems
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D
D
~-I .______I _
D D
D D
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D D D
~I I II._______
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352      Belyaev et al.: EUROPAEM EMF Guideline 2015
susceptibility, EHS symptoms often occur only occasion-
ally, but over time they may increase in frequency and
severity. On the other hand, if a detrimental EMF exposure
is sufficiently reduced, the body has a chance to recover
and EHS symptoms will be reduced or will vanish.
Variation of health problems depending on time,
location, and circumstances
The answers to questions of when and where the health
problems occur or recede, and when and where the
symptoms increase or are particularly evident, provide
only indications. They must be interpreted by the inves-
tigator (e.g. regarding the correct attribution between
location/EMF sources and health problems). Special
attention should be drawn to sleeping areas, because of
the duration of influence and the vital role of sleep for
regeneration.
Assessment of certain EMF exposures that can be
estimated by questionnaire
The assessment of EMF exposure usually starts with
certain questions of usual EMF sources. Regardless of
whether or not the patient suspects EMF exposure as a
cause, these questions should be used to assess the exist-
ing exposure level, at least as a rough estimate. It is impor-
tant to note that only certain types of EMF exposure can
be assessed by means of questions, such as the use of
compact fluorescent lamps (CFLs), cell phones, and cord-
less phones. Detection of other types of EMF exposure,
e.g. due to RF transmitter sites or the electric or magnetic
fields from electric wiring, generally requires measure-
ments. In principle, questions should be asked to assess
EMF exposure at home and at work and when on holidays
and so on, keeping in mind that the degree of EMF expo-
sure may vary at different times.
Examination and findings
We do not have any clinical findings yet that are specific
to EMF, which makes diagnosis and differential diagnosis
a considerable challenge.
A method that has proven useful is to use stress-
associated findings for diagnosis and followup and to
evaluate them synoptically. Basic diagnostic tests should
be carried out as a first step, followed by measurements
of EMF exposure as a second step. The core diagnosis
should focus on investigations of nitric oxide production
(nitrotyrosine), mitochondriopathy (intracellular ATP),
oxidative stress-lipid peroxidation (MDA-LDL) and inflam-
mation (TNF-alpha, INF-G (IP-10), IL-1b).
Then additional diagnostic tests can be considered.
Functional tests
Basic diagnostic tests
–Blood pressure and heart rate (in all cases resting
heart rate in the morning while still in bed), including
self-monitoring, possibly several times a day, e.g. at
different locations and with journaling of subjective
well-being for a week.
Additional diagnostic tests
– 24-h blood pressure monitoring (absence of nighttime
decline)
– 24-h ECG (heart rhythm diagnosis)
– 24-h heart rate variability (HRV) (autonomous nerv-
ous system diagnosis)
– Ergometry under physical stress
– Sleep EEG at home
Laboratory tests
Basic diagnostic tests
– Blood
– Bilirubin
– Blood count and differential blood count
– BUN
– Cholesterol, LDL, HDL, triglycerides
– Creatinine kinases (CK-MB, CK-MM)
– CRP
– Cystatin C (glomerular filtration rate)
– Electrolytes
– Fasting blood glucose
– Ferritin
– HBA1c
– Histamine and diaminoxidase (DAO)
– INF-G (IP-10)
– Interleukin-1 (e.g. IL-1a, IL-1b)
– Intracellular ATP
– Liver enzymes (e.g. ALT, AST, GGT, LDH, AP )
– Magnesium (whole blood)
– malondialdehyde-LDL
– Nitrotyrosine
– Potassium (whole blood)
– Selenium (whole blood)
– TSH
– Tumor necrosis factor alpha (TNFα)
– Vitamin D
– Zinc (whole blood)
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– Standard urine
– Leucocytes, erythrocytes, albumin, urobilinogen,
pH, bacteria, glucose, microalbumin
– Second morning urine
– 6-OH melatonin sulfate
– Adrenaline
– Dopamine
– Noradrenaline
– Noradrenaline/adrenaline quotient
– Serotonin
– Saliva
– Cortisol (8 a.m., 12 a.m., and 8 p.m.)
Additional diagnostic tests
– Urine
– Metals
– Second morning urine
– Gamma-aminobutyric acid (GABA)
– Glutamate
– Kryptopyrrole
– Saliva
–Dehydroepiandrosterone DHEA (8 a.m. and 8 p.m.)
– Blood
– 8-hydroxydeoxyguanosine (DNA oxidation)
– Biotin
– Differential lipid profile
– Folate
– Holotranscobolamin
– Homocysteine
– Interferon-gamma (IFNγ)
– Interleukin-10 (IL-10)
– Interleukin-17 (IL-17)
– Interleukin-6 (IL-6)
– Interleukin-8 (IL-8)
– Intracellular glutathione (redox balance)
– Lactate, pyruvate incl. ratio
– Lipase
– NF-kappa B
– Ubiquinone (Q10)
– Vitamin B6 (whole blood)
Provocation tests
Special facilities with the use of a variety of signals, e.g.
DECT or Wi-Fi exposure (e.g. 20–60 min, depending on
the individual regulation capacity, susceptibility, and
observed response)
– Heart rate variability (HRV) (autonomous nervous
system diagnosis)
– Microcirculation
–Oxidative stress (lipid peroxidation, malondialdehyde-
LDL)
Individual susceptibility
– Blood (genetic parameters and actual function)
– Glutathione S transferase M1 (GSTM1) –
detoxification
– Glutathione S transferase T1 (GSTT1) –
detoxification
– Superoxide dismutase 2 (SOD2) – protection of
mitochondria
– Catechol-O-methyltransferase (COMT) – stress
control
Measurement of EMF exposure
The evolutionary development of the human species took
place under the presence of the natural electromagnetic
spectrum (Earth’s magnetic field, Earth’s electric field,
spherics, Schumann resonance). Those influences have
been part of our biosphere like the oxygen content in the
air or the visible light spectrum, and they have been inte-
grated into the biological functions.
By now, nearly all nonionizing parts of the electro-
magnetic spectrum are filled with artificial, technical EMF
sources due to electrification and (wireless) communica-
tion technologies, but are very rarely found in nature (see
Figure 3). EMF measurements and/or exposure damages
are usually not covered by statutory health care insurance.
In general, a wide variety of EMF exposure types
should be considered: cordless phones (DECT), wireless
Internet access (Wi-Fi), electrical wiring and electrical
devices in buildings, compact fluorescent lamps (CFLs),
mobile phone base stations, radio and TV transmitters,
high-voltage power lines or transformer stations, and
“dirty electricity”.
In the sleeping area, the most important exposure
point is the head and trunk region followed by all other
points with chronic or high exposure.
EMF measurements should be planned and carried
out by specially trained and experienced testing special-
ists and always in accordance with relevant standards,
e.g. the VDB Guidelines of the German Association of
Building Biology Professionals (184). In addition to the
measurement results, the measurement report should
also include suggestions on how to possibly reduce the
EMF exposure.
To clarify certain issues, personal dosimeters with a
data logging function are available to measure ELF mag-
netic fields and radio-frequency radiation.
After the measurements have been commissioned
by the person and carried out, the results should be dis-
cussed with a physician familiar with the EMF issue.
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EMF guidance values
In each case, the following aspects should be individually
taken into account when evaluating EMF measurement
results (73):
–The person’s individual susceptibility
– The person’s individual total body burden (e.g. expo-
sure to noise, chemicals)
– Duration of EMF exposure
– EMF exposure during the night and day
– Multiple exposure to different EMF sources
– Signal intensity (W/m2, V/m, A/m)
–Signal characteristics (was taken into account in the
EMF guidance values – see Supplement 3)
–Frequency
– Risetime (∆T) of bursts, transients, etc.
– Frequency and periodicity of bursts, e.g. cer-
tain GSM base stations (8.3 Hz), Wi-Fi networks
(10 Hz), DECT cordless phones (100 Hz)
– Type of modulation (frequency modulation,
amplitude modulation, phase modulation)
Regardless of the ICNIRP recommendations for specific
acute effects, the following guidance values apply to
sensitive locations with long-term exposure of more than
20 h per week (185). They are based on epidemiological
studies (9, 10, 73, 186–189), empirical observations, and
measurements relevant in practice (190, 191) as well as
recommendations by the Parliamentary Assembly of the
Council of Europe (26). The proposed guidance values
are based on scientific data including a preventive com-
ponent and aim to help restore health and well-being in
already compromised patients/functionally impaired
persons.
Basic measurementsELF magnetic fields (extremely low frequency) (ELF MF)Measurement specifications
Frequency range: 50/60 Hz mains electricity, up to 2 kHz
16.7 Hz railroad systems in Austria, Germany,
Switzerland, Sweden, and Norway
Type of measurement: Magnetic induction or flux density
[T; mT; µT; nT]
Field probe: Isotropic magnetic field probe (three
orthogonal axes)
Detector mode: RMS (root mean square)
Measurement volume: Short-term: Bed: Complete sleeping area of bed
Short-term: Workplace: Complete working
space of workplace (e.g. sitting position)
Long-term: e.g. point close to the head/trunk in
bed or at workplace
Electromagnetic spectrum
Natural and artificial sources
1 Hz
100 10 Hz
101 100 Hz
102 1 kHz
103 10 kHz
104 100 kHz
105 1 MHz
106 10 MHz
107 100 MHz
108 1 GHz
109 10 GHz
1010 100 GHz
1011 1 THz
1012 10 THz
1013 100 THz
1014 1 PHz
1015 10 PHz
1016 100 PHz
1017 1 EHz
1018 10 EHz
1019 100 EHz
1020 1 ZHz
1021 10 ZHz
10220Hz20
Electromagnetic fields and radiation Ionizing radiationOptical radiation
ELF RF / MW RadiationVLF
Figure 3: Examples of natural (green) and artificial (red and blue) EMF sources along the electromagnetic spectrum (183).
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Measurement period: Short-term measurements to identify field
sources
Long-term measurements during sleep and
work shift
Basis for evaluation: Long-term measurements: maximum (MAX) and
arithmetic mean (AVG)
Precautionary guidance values
In areas where people spend extended periods of time ( > 4 h
per day), minimize exposure to ELF magnetic fields to levels
as low as possible or below the precautionary guidance
values specified below.
ELF magnetic
field
 Daytime
exposure
 Nighttime
exposure
 Sensitive
populations
Arithmetic
mean (AVG)
 100 nT
(1 mG)1),2)
 100 nT
(1 mG)1),2)
 30 nT
(0.3 mG)4)
Maximum
(MAX)
 1000 nT
(10 mG)2),3)
 1000 nT
(10 mG)2),3)
 300 nT
(3 mG)4)
Based on: 1)BioInitiative (9, 10); 2)Oberfeld (189); 3)NISV (192);
4) precautionary approach by a factor 3 (field strength).
Evaluation guidelines specifically for sleeping areas
Higher frequencies than the mains electricity at 50/60 Hz
and distinct harmonics should be evaluated more critically.
See also the precautionary guidance values for the interme-
diate frequency range further below. If applicable, mains
current (50/60 Hz) and traction current (16.7 Hz) should be
assessed separately but added (squared average). Long-
term measurements should be carried out especially at
nighttime, but at least for 24 h.
ELF electric fields (extremely low frequency) (ELF EF)
Measurement specifications
Frequency
range:
 50/60 Hz mains electricity, up to 2 kHz
16.7 Hz railroad systems in Austria, Germany,
Switzerland, Sweden, and Norway
Type of
measurement:
 Electric field [V/m] without ground reference
(potential-free) and/or body-current [A/m2] see
separate paragraph
Field probe: Isotropic electric field probe (three orthogonal axes)
Detector mode: RMS (root mean square)
Measurement
volume:
 Bed: nine points across sleeping area
Workplace: Complete working space (e.g. sitting
position three or six points)
Measurement
period:
 Spot measurements to asses the exposure as well as
to identify field sources. Since electric field exposure
levels in the ELF frequency range usually do not
change, long-term measurements are not needed.
Basis for
evaluation:
 Spot measurements (maximum) at relevant points
of exposure
Precautionary guidance values
In areas where people spend extended periods of time ( > 4 h
per day), minimize exposure to ELF electric fields to levels
as low as possible or below the precautionary guidance
values specified below.
ELF electric field  Daytime exposure  Nighttime exposure  Sensitive populations
Maximum
(MAX)
 10 V/m1),2) 1 V/m2) 0.3 V/m3)
Based on: 1)NCRP Draft Recommendations on EMF Exposure
Guidelines: Option 2, 1995 (188); 2)Oberfeld (189); 3)precautionary
approach by a factor 3 (field strength).
Evaluation guidelines specifically for sleeping areas
Higher frequencies than the mains electricity at 50/60 Hz
and distinct harmonics should be evaluated more critically.
See also the precautionary guidance values for the interme-
diate frequency range further below.
Radio-frequency electromagnetic radiation (RF EMR)
Measurement specifications
Frequency range: Radio and TV broadcast transmitters
Mobile phone base stations, e.g. TETRA (400 MHz),
GSM (900 and 1800 MHz), UMTS (2100 MHz),
LTE (800, 900, 1800, 2500–2700 MHz),
Cordless phone base stations, e.g. DECT (1900)
Wi-Fi access points and clients (2450 and
5600 MHz)
WiMAX (3400–3600 MHz)
(above frequencies in MHz refer to European
networks)
Type of measurement: Electric field [V/m] - >  calculated power density
[W/m2; mW/m2; µW/m2]
Field probe: Isotropic, biconical, logarithmic-periodic
antennas
Detector mode: Peak detector with max hold
Measurement volume: Point of exposure across bed and working
space
Measurement period: Usually short-term measurements to identify
RF field sources (e.g. acoustic analysis) and
peak readings
Basis for evaluation: Band-specific or frequency-specific spot
measurements (peak detector with max hold)
of common signals at relevant points of
exposure (e.g. with spectrum analyzer or at
least band-specific RF meter)
Precautionary guidance values for selected RF sources
In areas where people spend extended periods of time ( > 4 h
per day), minimize exposure to radio-frequency electro-
magnetic radiation to levels as low as possible or below the
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356      Belyaev et al.: EUROPAEM EMF Guideline 2015
precautionary guidance values specified below. Frequencies
to be measured should be adapted to each individual case.
The specific guidance values take the signal charac-
teristics of risetime (∆T) and periodic ELF “pulsing” into
account (191). Note: Rectangular signals show short rise-
times and consist of a broad spectrum of frequencies. The
body current density increases with increasing frequency in
an approximately linear relationship (Vignati and Giuliani,
1997).
RF sourceMax Peak/Peak Hold Daytime exposure  Nighttime exposure  Sensitive populations1)
Radio broadcast
(FM)
 10,000 µW/m2 1000 µW/m2 100 µW/m2
TETRA  1000 µW/m2  100 µW/m2  10 µW/m2
DVBT  1000 µW/m2  100 µW/m2  10 µW/m2
GSM (2G)
900/1800 MHz
 100 µW/m2  10 µW/m2  1 µW/m2
DECT (cordless
phone)
 100 µW/m2  10 µW/m2  1 µW/m2
UMTS (3G) 100 µW/m2  10 µW/m2  1 µW/m2
LTE (4G) 100 µW/m2  10 µW/m2  1 µW/m2
GPRS (2.5G) with
PTCCH*
(8.33 Hz pulsing)
 10 µW/m2  1 µW/m2  0.1 µW/m2
DAB+
(10.4 Hz pulsing)
 10 µW/m2  1 µW/m2  0.1 µW/m2
Wi-Fi
2.4/5.6 GHz
(10 Hz pulsing)
 10 µW/m2  1 µW/m2  0.1 µW/m2
*PTCCH, Packet Timing Advance Control Channel.
Based on: BioInitiative (9, 10); Kundi and Hutter (186); Leitfaden
Senderbau (187); Belyaev (73); PACE (26). 1)Precautionary approach
by a factor 3 (field strength) = factor 10 power density.
Conversion of RF measurement units
 mW/m2  10 1 0.1 0.01 0.001 0.0001
 µW/m2  10,000 1000 100 10 1 0.1
 µW/cm2 1 0.1 0.01 0.001 0.0001 0.00001
 V/m  1.9 0.6 0.19 0.06 0.019 0.006
Additional measurements
Body-current (extremely low frequency) (ELF BC)
The type of body current measurement has been devel-
oped in Germany (193) and is used by so-called electrobiol-
ogists (194). The methodology offers the possibility to assess
directly the relevant effect – the body current – caused by
electric and magnetic fields (195). To date, the effects of
electric fields on human health with a view to their distri-
bution and relevance to increase the body current density
are massively underestimated. We strongly recommend
to perform epidemiological studies (e.g. intervention,
case-control, cohort) for the health endpoints discussed
and – besides other EMF exposures – to take the follow-
ing measurements in this order: 1) body current (A/m2),
2) electric field (V/m) without ground reference (poten-
tial-free) without and with a person or a 3D dummy (not
grounded!) to simulate the conductive body. In order to
distinguish as to whether the measured body currents
are caused by electric or magnetic fields, the magnetic
fields have to be measured as well in all three axes. Long-
term measurements of ELF magnetic fields should be
performed with an isotropic magnetic field probe (three
orthogonal axes) according to the corresponding para-
graph in this chapter.
Measurement specifications
Frequency range: 50/60 Hz mains electricity, up to 2 kHz
16.7 Hz railroad systems in Austria,
Germany, Switzerland, Sweden, and
Norway
Type of measurement: Body-current [A/m2]
Field probe: Magnetic field probe (one orthogonal axis)
Detector mode: RMS (root mean square)
Measurement volume: 10 specific points close to the body
(head, trunk and limbs)
Measurement period: Spot measurements to asses the
exposure as well as to identify field
sources. As electric field exposure levels
in the ELF frequency range usually do not
change, long-term measurements are
not needed.
Basis for evaluation: Spot measurements (maximum) at
relevant points of exposure
Precautionary guidance values
In areas where people spend extended periods of time ( > 4 h
per day), minimize exposure to ELF body-current to levels
as low as possible or below the precautionary guidance
values specified below.
ELF body-current Daytime
exposure
 Nighttime
exposure
 Sensitive
populations
Maximum(MAX) 0.25 µA/m2 1) 0.25 µA/m2 1) 0.05 µA/m2 2),3)
Based on: 1)0.25 µA/m2 corresponds to 100 nT (RMS, AVG);
2)0.05 µA/m2 corresponds to 20 nT (RMS, AVG), Arbeitskreis
Elektrobiologie (194), based on empirical observations; 3)precau-
tionary approach by a factor 5 (field strength).
Evaluation guidelines specifically for sleeping areas
Higher frequencies than the mains electricity at 50/60 Hz
and distinct harmonics should be evaluated more critically.
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µ µ JJ.
µ µ II.
µ µ II.
µ µ II.
µ µ II.
µ µ II.
µ µ II.
µ µ µ
µ µ µ
µ µ µ
µ
Belyaev et al.: EUROPAEM EMF Guideline 2015      357
See also the precautionary guidance values for the inter-
mediate frequency range further below.
Magnetic fields in the intermediate frequency range
(VLF) (IF MF)
Measurement specifications
Frequency range: 3 kHz–3 MHz
Frequency-specific measurements
(spectrum analyzer/EMF meter), e.g. “dirty
power,” powerline communication (PLC),
radio-frequency identification transmitters
(RFID), compact fluorescent lamps (CFL)
Type of measurement: Magnetic field [A/m] - >  calculated magnetic
induction [T; mT; µT; nT]
Field probe: Isotropic or anisotropic magnetic field probe
Detector mode: RMS (root mean square)
Measurement volume: Point of exposure across bed and working
space
Measurement period: Short-term measurements to identify field
sources
Long-term measurements during sleep and
work shift
Basis for evaluation: Long-term measurements: RMS detector
arithmetic mean and maximum at relevant
points of exposure
Precautionary guidance values
In areas where people spend extended periods of time
( > 4 h per day), minimize exposure to intermediate fre-
quency magnetic fields to levels as low as possible or
below the precautionary guidance values specified
below.
4)The body current density increases with increas-
ing frequency in an approximately linear relationship
(Vignati and Giuliani, 1997). Therefore, the guidance
value of the magnetic field in the intermediate frequency
range should be lower than the one of the 50/60 Hz mag-
netic field, e.g. assuming 100 nT RMS/100 = 1 nT.
IF magnetic field  Daytime exposure  Nighttime exposure  Sensitive populations
Arithmetic
mean
 1 nT
(0.01 mG)1),2)
 1 nT
(0.01 mG)1),2)
 0.3 nT
(0.003 mG)4)
Maximum  10 nT
(0.1 mG)2),3)
 10 nT
(0.1 mG)2),3)
 3 nT
(0.03 mG)4)
Based on: 1)BioInitiative (9, 10); 2)Oberfeld (189); 3)NISV (192);
4) precautionary approach by a factor 3 (field strength).
Electric fields in the intermediate frequency range
(VLF) (IF EF)
Measurement specifications
Frequency range: 3 kHz–3 MHz
Frequency-specific measurements
(spectrum analyzer/EMF meter), e.g.
“dirty power,” powerline communication
(PLC), radio-frequency identification
transmitters (RFID), compact fluorescent
lamps (CFL)
Type of measurement: Electric field [V/m]
Field probe: Isotropic, biconical, logarithmic-periodic
electric field probe
Detector mode: RMS arithmetic mean
Measurement volume: Point of exposure across bed and
working space
Measurement period: Short-term measurements to identify
field sources
Long-term measurements during sleep
and work shift
Basis for evaluation: Long-term measurements: arithmetic
mean at relevant points of exposure
Precautionary guidance values
In areas where people spend extended periods of time ( > 4 h
per day), minimize exposure to intermediate frequency
electric fields to levels as low as possible or below the pre-
cautionary guidance values specified below.
4)The body current density increases with increasing
frequency in an approximately linear relationship (Vignati
and Giuliani 1997). Therefore, the guidance value of the
magnetic field in the intermediate frequency range should
be lower than the one of the 50/60 Hz magnetic field,
e.g. assuming 10 V/m RMS arithmetic mean/100 = 0.1 V/m.
IF electric field  Daytime
exposure
 Nighttime
exposure
 Sensitive
populations
Arithmetic mean  < 0.1 V/m1),2)  < 0.01 V/m2)  < 0.003 V/m3)
Based on: 1)NCRP Draft Recommendations on EMF Exposure
Guidelines: Option 2, 1995 (188); 2)Oberfeld (189); 3)precautionary
approach by a factor 3 (field strength).
Static magnetic fields
Measurement specifications
Frequency range: 0 Hz
Type of measurement: Magnetic induction or flux density
[T; mT; µT; nT]
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358      Belyaev et al.: EUROPAEM EMF Guideline 2015
Field probe: Anisotropic magnetic field probe (for one
spatial axis – vertical) or Isotropic magnetic
field probe (three orthogonal axes)
Detector mode: RMS (root mean square)
Measurement volume: Point of exposure across bed and working
space
Measurement period: Short-term measurements to identify field
sources that distort the Earth’s magnetic
field
Basis for evaluation: Spot measurements (RMS maximum) at
relevant points of exposure
Precautionary guidance values
In areas where people spend extended periods of time ( > 4 h
per day), minimize exposure to static magnetic fields that
distort the naturally occurring Earth’s magnetic field to
levels as low as possible.
Evaluation guidelines specifically for sleeping areas
First determine the natural background level in a reference
location, e.g. close to the bed. The field probe must not be
moved during the measurement process in order to prevent
false readings due to induced currents by the Earth’s mag-
netic field. The guidance values below are meant in addi-
tion to the Earth’s magnetic field.
Static magnetic field  No anomaly  Slight anomaly  Significant anomaly  Extreme anomaly
Deviation
from natural
background
   ≤  1 µT 
 ≤  10 mG
 1–2 µT
10–20 mG
 2–10 µT
20–100 mG
  > 10 µT 
> 100 mG
Based on: Building Biology Evaluation Guidelines (SBM-2015) (190),
which are based on empirical observations.
Static electric fields
Measurement specifications
Frequency range: 0 Hz
Type of measurement: Electric field [V/m]
Field probe: Anisotropic or isotropic electric field probe
Detector mode: RMS (root mean square)
Measurement volume: Point of exposure across bed and
working space
Measurement period: Short-term measurements to identify
field sources
Basis for evaluation: Spot measurements (maximum) at
relevant points of exposure
Precautionary guidance values
In areas where people spend extended periods of time ( > 4 h
per day), minimize exposure to static electric fields that
exceed the naturally occurring fair-weather atmospheric
electric field.
Evaluation guidelines specifically for sleeping areas
Static electric field No anomaly Slight anomaly  Significant anomaly  Extreme anomaly
Maximum   < 100 V/m  100– 500 V/m 500– 2000 V/m   > 2000 V/m
Based on: Building Biology Evaluation Guidelines (SBM-2015) (190),
which are based on empirical observations.
Prevention or reduction of EMF exposure
Preventing or reducing EMF exposure after consulting a
testing specialist is advantageous for several reasons:
a) To prevent and reduce risks to individual and public
health,
b) To identify any links to health problems,
c) To causally treat the EMF-related health problems.
There are numerous potential causes of relevant EMF
exposures, and this EMF Guideline can only give a
few examples. Further information can be found, for
instance, in the document “Options to Minimize EMF/
RF/Static Field Exposures in Office Environments” (196)
and “Elektrosmog im Alltag” (197). For detailed informa-
tion on physics, properties and measurement of EMF, see
Virnich (198); regarding reduction of radio-frequency
radiation (RFR) in homes and offices, see Pauli and
Moldan (199).
In most cases, it will be necessary to consult an expert
(e.g. building biology testing specialist, EMF/RF engineer)
and/or electrician who will advise the person on what
measures could be taken to reduce EMF exposure.
EMF exposure reduction – First steps
As a first step, it might be useful to recommend to persons
that they take certain actions (also as preventive meas-
ures) to eliminate or reduce typical EMF exposures, which
may help alleviate health problems within days or weeks.
The following actions may be suggested:
Preventing exposure to radio-frequency radiation
(RFR)
– Disconnect (unplug) the power supply of all DECT
cordless phone base stations. So called “ECO Mode” or
“zero-emission” DECT phones are only conditionally
recommended because the exposure by the handset is
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Belyaev et al.: EUROPAEM EMF Guideline 2015      359
not or not substantially reduced. Therefore, the use of
“traditional” corded phones is recommended.
– Disconnect (unplug) the power supply to all Wi-Fi
access points or Wi-Fi routers. Many LAN routers
now come equipped with additional Wi-Fi. Call the
provider of the LAN router and ask to have the Wi-Fi
deactivated. It is usually also possible to do so online
by following the provider’s instructions.
– Avoid wearing the cell phone/smartphone close to the
body.
– Deactivate all nonessential wireless cell phone apps,
which cause periodic radiation exposure.
– Keep cell phones/smartphones in “airplane mode”
whenever possible.
– In case of external RF radiation sources, rooms – espe-
cially sleeping rooms – facing away from the source
should be chosen.
– Avoid powerline communication for Internet access
(dLAN) and instead use a hardwired Ethernet cable
(LAN).
– Avoid exposure to RF radiation (e.g. Bluetooth, Wi-Fi)
at home (e.g. home entertainment, headsets), in
offices, and in cars.
Preventing exposure to ELF electric and magnetic
fields
– Move the bed or desk away from the wiring in the
walls and power cords. A minimum distance of 30 cm
(1 ft) from the wall is recommended.
– Another simple complementary action is to discon-
nect the power supply to the bedroom (turn off cir-
cuit breaker or fuse) for the nighttime while sleeping;
try it for a test phase of, e.g. 2 weeks. In general, this
measure is not always successful because circuits of
adjacent rooms contribute to the electric field lev-
els. ELF electric field measurements are required
to know exactly which circuit breakers need to be
disconnected.
The benefits should be weighed against the potential
risk of accidents; therefore, the use of a flashlight for
the test phase should be recommended.
– Disconnect the power supply to all nonessential elec-
tric circuits, possibly in the entire apartment or house.
(N.B. See note above.)
– Avoid using an electric blanket during sleep; not only
turn it off, but also disconnect it.
Preventing exposure to static magnetic fields
– Sleep in a bed and mattress without metal.
– Avoid to sleep close to iron materials (radiator, steel,
etc.)
EMF exposure reduction – second steps
As a second step, EMF measurements and mitigation
measures should be carried out. Typical examples are:
– Measure the ELF electric field in the bed or the body
current density of the person while in bed. Based on
the measurement results, have automatic demand
switches in those circuits installed that increase the
exposure.
– Measure the ELF electric field at all other places that
are used for extended periods at home and at work. If
necessary, choose lamps used close to the body with
a shielded electric cable and a grounded lamp fixture
(metal). Especially in lightweight construction (wood,
gypsum board), electrical wiring without ground-
ing (two-slot outlets) might have to be replaced with
grounded electrical wiring or shielded electrical wir-
ing. In special cases, the whole building might have
to have shielded wiring and shielded outlets installed.
– Measure the ELF magnetic field close to the bed, e.g.
for 24 h. If net currents are detected, the electrical wir-
ing and grounding system of the building must be cor-
rected as to reduce the magnetic fields.
– Install a residual current device (RCD) or ground-fault
circuit interrupter (GFCI) to prevent electric shocks
(safety measure).
– Measure radio-frequency radiation and mitigate high
exposure levels by installing certain RF shielding
materials for the affected walls, windows, doors, ceil-
ings, and floors.
– Measure dirty electricity/dirty power (electric and
magnetic fields in the intermediate frequency range)
and identify the sources in order to remove them. If
this is not possible, appropriate power filters in line
with the source may be used.
Diagnosis
We will have to distinguish between EHS and other EMF-
related health problems like certain cancers, Alzheimer’s,
ALS, male infertility etc. that might have been induced,
promoted, or aggravated by EMF exposure. An inves-
tigation of the functional impairment EHS and other
EMF-related health problems will largely be based on a
comprehensive case history, focusing, in particular, on
correlations between health problems and times, places,
and circumstances of EMF exposure, as well as the pro-
gression of symptoms over time and the individual sus-
ceptibility. In addition, measurements of EMF exposure
and the results of additional diagnostic tests (labora-
tory tests, cardiovascular system) serve to support the
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diagnosis. Moreover, all other potential causes should be
excluded as far as possible.
In 2000 the Nordic Council of Ministers (Finland,
Sweden, and Norway) adopted the following ICD-10 code
for EHS: Chapter XVIII, Symptoms, signs and abnormal
clinical and laboratory findings, not elsewhere classified,
code R68.8 “Other specified general symptoms and signs”
(Nordic ICD-10 Adaptation, 2000) (200).
Regarding the current International Classification of
Diseases (ICD), ICD-10-WHO 2015, we recommend at the
moment:
a) Electromagnetic hypersensitivity (EHS): to use the
existing diagnostic codes for the different symptoms
plus code R68.8 “Other specified general symptoms
and signs” plus code Z58.4 “Exposure to radiation”
and/ or Z57.1 “Occupational exposure to radiation”.
b) EMF-related health problems (except EHS): to use the
existing diagnostic codes for the different diseases/
symptoms plus code Z58.4 “Exposure to radiation”
and/or Z57.1 “Occupational exposure to radiation”.
Regarding the next ICD-update (ICD-11 WHO) to be pub-
lished 2018), we recommend to:
a) Create ICD codes for all chronic environmentally
induced chronic multisystem illnesses (CMI) like mul-
tiple chemical sensitivity (MCS), chronic fatigue syn-
drome (CFS), fibromyalgia (FM), and electromagnetic
hypersensitivity (EHS).
b) Expand Chapter XIX, Injury, poisoning and certain
other consequences of external causes (T66-T78) to
include/distinguish effects of EMF (static magnetic
field, static electric field, ELF magnetic field, ELF
electric field, VLF/LF magnetic field, VLF/LF electric
field, Radio-frequency electromagnetic radiation)
infrared, visible light, UV-light and ionizing radiation.
c) Expand Chapter XXI, Factors influencing health status
and contact with health services (Z00-Z99) to include/
distinguish factors as EMF (static magnetic field,
static electric field, ELF magnetic field, ELF electric
field, VLF/LF magnetic field, VLF/LF electric field,
Radio-frequency electromagnetic radiation), infra-
red, visible light, UV-light, and ionizing radiation.
Treatment/accessibility measure
The primary method of treatment should mainly focus on
the prevention or reduction of EMF exposure that is reduc-
ing or eliminating all sources of EMF at home and in the
workplace. The reduction of EMF exposure should also be
extended to schools, hospitals, public transport, public
places like libraries, etc. in order to enable EHS persons
an unhindered use (accessibility measure). Many exam-
ples have shown that such measures can prove effective.
With respect to total body load of other environmental
influences, they must also be regarded.
Beside EMF reduction, other measures can and must
be considered. These include a balanced homeostasis in
order to increase the “resistance” to EMF. There is increas-
ing evidence that a main effect of EMF on human beings
is the reduction of oxidative and nitrosative regulation
capacity. This hypothesis also explains observations of
changing EMF sensitivity and the large number of symp-
toms reported in the context of EMF exposure. From the
current perspective, it appears useful to recommend a
treatment approach, as those gaining ground for multi-
system disorders, that aims at minimizing adverse perox-
ynitrite effects.
It should be stressed, that psychotherapy has the
same significance as in other diseases. Products that are
offered in the form of plaques and the like to “neutralize”
or “harmonize” electrosmog should be evaluated with
great restraint.
In summary, the following treatment and accessibility
measures appear advantageous, depending on the indi-
vidual case:
Reduction of EMF exposure
This should include all types of EMF exposures relevant to
the person, especially during sleep and at work. For more
information, see e.g. “Options to Minimize EMF/RF/Static
Field Exposures in Office Environment” (196) and “Elek-
trosmog im Alltag” (197).
Environmental Medicine treatments
Until now, no specific treatment of EHS has been estab-
lished. Controlled clinical trials would be necessary to
assess optimal treatment and accessibility measures.
Actual data indicate that the functional deficits, which can
be found in persons with EHS, correspond to those we can
find in CMI such as MCS, CFS, and FM. The target of the
therapy is the regulation of the physiological dysfunction
detected by diagnostic steps (Examination and findings).
The main therapeutic target includes both general and
adjuvant procedures and specific treatments. The latter
are challenging and need special knowledge and experi-
ence in clinical environmental medicine treatments. Main
therapeutic targets include:
–Control of total body burden
Besides the reduction of EMF exposure, the
reduction of the total body burden by various
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environmental pollutants (home, working place,
school, hobby), food additives, and dental materi-
als is indicated.
–Reduction of oxidative and/or nitrosative stress
Reactive oxygen species (ROS) and reactive nitrogen
species (RNS) are free radicals naturally produced
in cells. Scavengers guarantee the balance between
the production of free radicals and the rate of their
removal. Many biologically important compounds
with antioxidant (AO) function have been identified
as endogenous and exogenous scavengers. Among the
endogenous AO, we distinguish between enzymatic
AO (catalase, glutathione peroxidase, glutathione
reductase, superoxide dismutase) and nonenzymatic
AO (bilirubin, ferritin, melatonin, glutathione, metal-
lothionin, N-acetyl cysteine (NAC), NADH, NADPH,
thioredoxin, 1,4,-bezoquinine, ubiquinone, uric acid).
They interact with exogenous dietary and/or synthetic
AO (carotenoids, retinoids, flavonoids, polyphenols,
glutathione, ascorbic acid, tocopherols). The complex
regulation and use of these substances is the thera-
peutic challenge (163, 201).
–Regulation of intestinal dysfunction
Endogenous and exogenous scavengers act synergis-
tically to maintain the redox homeostasis. Therefore,
dietary or natural antioxidants play an important role
to stabilize this interaction.
Treatment of a leaky gut, food intolerance, and food
allergy is a prerequisite for maintaining redox homeo-
stasis (202) and also requires special knowledge and
experience.
–Optimizing nutrition
Bioactive food is the main source of antioxidant com-
ponents such as vitamin C, vitamin E, NAC, carot-
enoids, CoQ10, alpha-lipoic acid, lycopene, selenium,
and flavonoids (203, 204). For instance, the regenera-
tion of vitamin E by glutathione or vitamin C is needed
to prevent lipid peroxidation. The dietary antioxidants
only can have beneficial effects on the redox system
if they are present in sufficient concentration levels
(201). Alpha-lipoic acid acts directly and indirectly as
a scavenger of free radicals including peroxynitrite,
singlet oxygen, superoxide, peroxyl radicals, and the
breakdown radicals of peroxynitrite (163). It had been
shown that the number of free electrons in micronu-
trients determines how effective they are. In organic
food, the number of free electrons is higher than in
conventionally produced food (205). Especially in
the case of food intolerances, the tailored substitu-
tion of micronutrients in the form of supplements is
necessary.
–Control of (silent) inflammation
Elevated nitric oxide levels and the reaction with
superoxide always leads to elevated peroxynitrate
levels, which induce ROS levels as no other substance
does (NO/ONOO− cycle). As a result, the nuclear
factor κB (NF-κB) is activated, inducing inflammatory
cytokines such as tumor necrosis factor α (TNF-α),
interleukin-1β (IL-1β), interleukin-6 (IL-6), interkeu-
kin-8 (IL-8), and interferon gamma (IFNγ) and acti-
vating various NO synthases (163). Tocopherols (206,
207), carotinoids at low concentration levels (208),
vitamin C (209, 210), NAC (211), curcumin (212), res-
veratrol (213, 214), flavonoids (215) have shown to
interrupt this inflammatory cascade at various points.
–Normalization of mitochondrial function
Mitochondrial function may be disturbed in two ways.
First: the high amount of free radicals may block pro-
duction of adenosine triphosphate (ATP), leading to
muscle pain and fatigue. Second: in the case of silent
(smoldering) inflammation, the demand for more
energy is elevated by 25% (167), causing a high con-
sumption of ATP. In this case, NADH, L-carnitine and
CoQ10 are essential for ATP synthesis.
Due to the lack of ATP, the stress regulation of catecho-
lamines especially norepinephrine (NE) is reduced
because catabolism of NE by S-adenosylmethionine
is ATP dependent (216–218). Furthermore, stress regu-
lation has a high demand for folate, vitamin B6, and
methylcobalamine. Genetic polymorphisms of COMT
and MTHFR influence the individual need for those
substances (173, 219).
–Detoxification
In humans, the accumulation of environmental toxi-
cants has an individual profile of many different inor-
ganic and organic chemicals, which make up the total
body load (220).
Among the inorganic substances, metals and their
salts play the dominant role and might be of impor-
tance to persons with EHS. Elemental mercury (Hg°)
and other heavy metals such as lead (Pb) accumu-
late in the brain (221), especially at chronic low
dose exposure. They may have toxic effects and can
induce various immune reactions (222, 223). Whereas,
generally, no specific active substance exists for the
detoxification of chemicals, there are two groups of
substances with more specific effects that can be used
for the detoxification of metals.
1. Substances with nonspecific physiological
effects:
Glutathione, NAC, alpha-lipoic acid, vitamin C
and selenium.
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2. Chelating agents for detoxification of metals
(224–226)
The most important chelating agents are:
Sodium thiosulfate 10%
DMPS (2,3-dimercapto-1-propanesulfonic acid)
DMSA (meso-dimercaptosuccinic acid)
EDTA (2,2′,2″,2″′-ethane-1,2-diyldinitrotetraacetic
acid)
It should be noted that these substances should
be used only by those designated as experts in
this particular field.
–Adjuvant therapies
1. Drinking water
For detoxification reasons, a higher intake of high-
quality drinking water with low mineral content and
no CO2 is needed. The intake quantity should range
from 2.5 to 3.0 L (10–12 8-oz glasses) daily.
2. Light
Most of the people in central and northern Europe
are depleted of vitamin D. Sufficient natural daylight
exposure during the vitamin D-producing months
(spring to fall) is one important factor. At the same
time, prevention of actinic damage to the skin is
necessary.
3. Sauna
Sauna and therapeutic hyperthermia is an adjuvant
therapy for the detoxification of almost all xenobi-
otics. These therapies have to be carefully used. An
interaction with detoxifying drugs takes place. Sauna
helps to regenerate tetrahydrobiopterin from dihyd-
robiopterin, which is essential for the metabolism of
catecholamines and serotonin (163).
4. Oxygen
A part of persons with EHS suffer from mitochondrial
dysfunction. Sufficient natural oxygen is helpful. As
both hypoxia and hyperbaric oxygen can produce oxi-
dative stress, hyperbaric oxygen therapy should only
be performed if the persons are treated with sufficient
antioxidants at the same time.
5. Exercise
The optimal amount of exercise is still being debated.
A person’s physical capacity should be assessed by
ergometry in order to prescribe an individual exercise
regime. Environmental medicine experience indicates
that for sick people only low-impact aerobic exercise
should be used. In general, start with a work load of
20–30 watts that often can be finished at 60–70 watts.
Exercise on an ergometer allows better control of
the consumption of energy compared to walking or
running. No fatigue should result from exercising, at
least after half an hour.
6. Sleep
Sleeping disorders are very common in persons with
EHS. Sleep disturbance is associated with reduced
melatonin level. In the case of chronic inflammation,
the activation of IDO (indolamine-2,3-dioxygenase)
reduces the production of serotonin and, in turn, it
also reduces melatonin levels. EMF exposure might
block the parasympathetic activity while sympathetic
activity persists. Concerning sleep disturbances, any
therapy has to follow the pathogenic causes. Optimal
sleep is necessary to save energy and to regulate
the functions of the immune and neuroendocrine
systems.
7. Protection from blue light
Wavelengths of visible light below 500 nm are called
“blue light”. Low doses of blue light can increase feel-
ings of well-being, but larger amounts can be harmful
to the eyes. In natural daylight, the harmful effects
of “blue light” are balanced out by the regenerative
effect of the red and infrared content. The escalating
use of electronic light sources – such as fluorescent
tubes and compact fluorescent lamps (CFL), computer
screens, laptops, tablets, smartphones, and certain
LED bulbs – has increased our exposure to “blue
light”, which at this level is suspected of playing a
role in the development of age-related macular degen-
eration and circadian misalignment via melatonin
suppression, which is associated with the increased
risk of sleep disturbance, obesity, diabetes melli-
tus, depression, ischemic heart disease, stroke, and
cancer. Extended exposure to artificial “blue light”
in the evening should therefore be limited. Antioxi-
dants, especially melatonin (227, 228) and blue light
screen filters (229–231) could be helpful.
Dental medicine
Dental medicine still works with toxic or immunoreactive
materials, e.g. mercury, lead oxide, gold, and titanium.
Environmental dental medicine demands that these mate-
rials not be used (232–235). The removal of toxic dental
materials must take place under maximum safety condi-
tions (avoid inhalation!). The elimination of particularly
heavy metals from the body might be indicated. In general
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terms, endoprosthetic materials should be inert with
respect to immunoreactivity. Based on our current knowl-
edge, zirconium dioxide seems to be a neutral material.
However, mechanical abrasion of the coated surface by
the dentist should be avoided.
Immunotoxic metals show a similar pathophysiology
with respect to oxidative stress, mitochondriopathy, and
inflammation.
Lifestyle coaching
Lifestyle coaching may include balanced exercise,
nutrition, reduction of addictive substances, change
of sleeping habits, etc. and stress reduction measures
(reduction of general stress and work stress), as well as
methods to increase stress resistance via, e.g. autogenic
training, yoga, progressive muscle relaxation, breathing
techniques, meditation, tai chi, and qigong.
Treatment of symptoms
A well-balanced treatment of symptoms is justified until
the causes have been identified and eliminated. However,
it is of paramount importance to realize that the reduction
of symptoms may put the person at risk for an increased
environmental EMF-load, thus generating possible future,
long-term health effects, including neurological damage
and cancer. It is a very difficult ethical task for the physi-
cian to risk such, and they must be pointed out – in an
equally well-balanced way – to the patient in question.
Ethically, to treat the symptoms is, of course, a very good
start in the immediate sense but without a parallel envi-
ronmental exposure reduction and lifestyle coaching it
may prove counter-productive in the long run. For a stand-
ardly trained physician this might seem a very new way
of reasoning, but is the only way to a successful and ever-
lasting symptom alleviation and complete clinical remedy
when dealing with chronic multisystem illnesses (CMI)
and EHS.
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PHYSICIANS STATEMENT – Exhibit 2
122
PRELIMINARY
Clinical Practice Guidelines in the Diagnosis and Management of Electromagnetic Field
Hypersensitivity (EHS)
Dr. Riina Ines Bray BASc, MSc, MD, FCFP, MHSc
Medical Director, Environmental Health Clinic, Women’s College Hospital
Assistant Professor, Department of Family and Community Medicine and Dalla Lana School of
Public Health, University of Toronto
[e-mail]
www.womenscollegehospital.ca/care-programs/environmental-health-clinic/
October, 2020
Introduction
Environmental health is the study of effects upon human beings of external physical/ electromagnetic,
chemical and biological factors in air, water, soil, food and other environmental media which impact on
the general population as well as genetic aberrations and psychosocial stressors.1 Environmental health is
an evidence- and public- health-based discipline. The physical environment is a determinant of health and
is interrelated with socioeconomic, social-justice and equity issues. The impact of the environment is an
especially important part of our public health domain.2
In 2014, a systematic review of 63 studies3 revealed that despite heterogeneity, the criteria predominantly
used to identify idiopathic environmental intolerance attributed to electromagnetic fields (IEI-EMF)
individuals were:
1.Self-report of being (hyper)sensitive to electromagnetic fields (EMF)
2.Attribution of non-specific physical symptoms (NSPS) to at least one EMF source
3.Absence of medical or psychiatric/psychological disorder capable of accounting for these
symptoms
4.Symptoms should occur soon (up to 24 hours) after the individual perceives an exposure source
or exposed area
Electromagnetic Field Hypersensitivity (EHS) is a spectrum disorder in which there is an awareness
and/or adverse response to electromagnetic fields.4 Environmental Sensitivities are recognized as a
disability under the Canadian Human Rights Commission (Federal).5
Demographics
EHS can occur in all age groups, genders (women are more genetically predisposed6), races and income
levels. Since 2005, the physicians at the Environmental Health Clinic at Women’s College Hospital have
assessed an increasing number of patients who, due to co-morbid conditions coupled with chronic
1 NEHA. Definitions of Environmental Health. https://www.neha.org/about-neha/definitions-environmental-health.
2 Electromagnetic hypersensitivity: fact or fiction? Genuis SJ. Lipp CT. Sci Total Environ. 2012; 414:103-12. 3 Idiopathic environmental intolerance attributed to electromagnetic fields (IEI-EMF): A systematic review of identifying criteria.
Baliatsas C. Van Kamp I. Lebret E. et al. BMC Public Health. 2012; 12(1).
4 Electrosensibility and electromagnetic hypersensitivity. Leitgeb N. Schrottner J. Bioelectromagnetics. 2003; 24(6):387-94.
5 Canadian Human Rights Commission. Environmental sensitivity and scent-free policies. https://www.chrc-
ccdp.gc.ca/eng/content/policy-environmental-sensitivities. 2019. 6 Belpomme, D.; Irigaray, P. Electrohypersensitivity as a Newly Identified and Characterized Neurologic Pathological Disorder:
How to Diagnose, Treat, and Prevent It. Int. J. Mol. Sci. 2020, 21, 1915.
123
exposures to electromagnetic fields. Patients present to the clinic after become unwell with a pattern of
functional impairments, some becoming disabled, losing their jobs or becoming homeless. Prolonged
and/or excessive exposures to these factors cause functional impairments in individuals, and a huge
burden of suffering.7

Etiology and Pathophysiology

The pathophysiology is poorly characterized. The degree of functional impairment caused by EMF
exposure is dependent upon genetic polymorphisms8 that predispose the individual to a poor
detoxification profile and therefore an increased total body burden (Figure 1). A poor detoxification
profile can also lead to co-morbid illnesses such as Multiple Chemical Sensitivities (MCS), nervous,
cardiac and immune system dysfunction which renders a person vulnerable to EMF exposures. Most
commonly, patients have had prolonged chronic exposures to radiofrequency radiation, microwaves,
electrical and/or magnetic fields from either wired or wireless technology. Patients can react to electric
fields (measured in volts per meter), magnetic fields (measured in milligauss or nano Tesla), dirty
electricity (high frequency voltage transients, which are deviations from a pure 50-60H Hz sine wave),
radiofrequency radiation, microwave radiation, ground currents and electrosmog.

The severity of the impact appears to depend upon the nature, dose, and timing of exposures, as well as a
person’s allostatic load, which is the maximum tolerated dose for combined environmental stressors.9
Patients can be identified as having environmental sensitivities, electrical sensitivities or as being “EMF
sensitive” or “EMF susceptible” rather than “hyper” in order to decrease stigmatization potential.

Radiofrequency radiation can cause the following adverse biological effects:10 11
• Cerebral hypoperfusion/ hypoxia-related neuroinflammation
• Histamine release causing oxidative stress in biological systems12
• Peroxidation, DNA damage, changes to antioxidant enzymes
• Voltage gated calcium channel dysregulation effecting the cardiac and nervous system
• Peroxynitrite formation which causes chronic inflammation, damage to mitochondrial function
and structure and reduction of ATP
• Reduced glutathione and CoQ10
• TRPV1 receptor activation13 14

Radiofrequency radiation and microwaves can cause thermal (heat related) or non-thermal effects. Under
the non-thermal category, adverse physiological effects have been identified including DNA damage,
immune system suppression, increased blood-brain barrier permeability, increased blood viscosity with
rouleaux formation.

7 Johansson O. Electrohypersensitivity: a functional impairment due to an inaccessible environment. Reviews on environmental
health. 2015 Dec 1;30(4):311-21.
8 De Luca C, Thai JC, Raskovic D, Cesareo E, Caccamo D, Trukhanov A, Korkina L. Metabolic and genetic screening of
electromagnetic hypersensitive subjects as a feasible tool for diagnostics and intervention. Mediators Inflamm. 2014;2014:924184 9 Selye H. (1946). The general adaptation syndrome and the diseases of adaptation. The Journal of clinical endocrinology and
metabolism, 6, 117–230. https://doi.org/10.1210/jcem-6-2-117
10 Martin Pall; De Luca/ Herbert and Sage
11 Belpomme, Dominique, Philippe Irigaray. “Electrohypersensitivity as a Newly Identified and Characterized Neurologic
Pathological Disorder: How to Diagnose, Treat, and Prevent It” Int. J. Mol. Sci. 2020; 21,1915. 12 Yakymenko I. Oxidative mechanisms of biological activity of low-intensity radiofrequency radiation. Electromagn Bio Med.
2016;35(2):186-202
13 Ertilav K, Uslusoy F, Ataizi S, Nazıroğlu M. Long term exposure to cell phone frequencies (900 and 1800 MHz) induces
apoptosis, mitochondrial oxidative stress and TRPV1 channel activation in the hippocampus and dorsal root ganglion of rats. Metab
Brain Dis. 2018 Jun;33(3):753-763 14 Ghazizadeh V, Nazıroğlu M. Electromagnetic radiation (Wi-Fi) and epilepsy induce calcium entry and apoptosis through
activation of TRPV1 channel in hippocampus and dorsal root ganglion of rats. Metab Brain Dis. 2014 Sep;29(3):787-99.
124
Figure 1: Total Toxic Load (Bray and Marshall, 2005)

History

The clinician is advised to:

1. Conduct a complete exposure history using the CH2OPD2 mnemonic15 16 to determine total
toxic load in the form of EMF/ RFR exposure, toxic metal exposure sources (diet, water,
prosthetics, implants, gadolinium), mould, and other potentially toxic chemical exposures.

15 Marshall et al, 2002
16 Bray, 2020
https://static1.squarespace.com/static/593f8894e3df288fc64b6cf0/t/598bbabdf14aa18c52a6dcce/1502329836033/Environmental+H
ealth+Clinic+Pre-Visit+Questionnaire.pdf
125
Total Load
Symptoms
Medi tio
Mold
·1~no·,
R.idhtboa
molmUt / AICOIM>l
Dl!l OXIFICATION
CH2OPD2 mnemonic
• Community
• Home
• Hobby
• Occupation
• Personal habits
• Diet
• Drugs

2. Determine specific community, work, school and home exposures to EMFs: proximity of cell
phone towers, routers, DECT cordless phones, any other wireless technology. Most importantly,
determine if the sleeping area is affected.17 18

A helpful mnemonic to determine the parameters of exposure is (F.I.N.D.)19
• F- frequency (Hertz)
• I- intensity (Power in µW/m2)
• N- nearness
• D- duration

3. Have a high index of suspicion for immune deficiencies (which can, for example, lead to candida
infection), gut dysbiosis and possible mast cell activation disorder (MCAS).

Symptoms Commonly Occurring Singularly or in Combination:

• Irritability, lack of appetite, memory problems, vertigo; visual, skin and vascular problems20
• Tinnitus, sleep disorders (disrupted stage 4 sleep with alpha wave intrusions and reduced
REM21) mood changes (anxiety, depression, irritability, panic attacks)22
• Headache, weakness, pressure in the head, racing or fluttering heart23
• Dermatological: itch, pain, edema, erythema secondary to elevated transthyretin concentrations24
• Neurasthenic and vegetative symptoms: fatigue, tiredness, cognitive problems, concentration
difficulties, dizziness, nausea, heart palpitations (tachycardia, PACs and PVCs), and digestive
disturbances25

Etiology of Common Clinical Presentations

Category I
Patients can present with a toxic metal body burden, most commonly mercury, due to the
overconsumption of aquatic, contaminated seafood. Methylmercury (half-life of 27 years in the brain) is
neurotoxic causing axonal demyelination and inflammation. Zinc/nickel/mercury dental amalgams also
release elemental mercury vapour which enters the brain through the olfactory bulb, and then is converted
to methylmercury. Patients can present with cardiac and neurological manifestations. Those with metallic
17 Maes B. Standard of building biology testing methods. Inst. Building Biol.+ Sustainability IBN, Rosenheim, Germany, Tech. Rep.
SBM-2008. 2008. 18 Maes B. Building Biology Evaluation Guidelines. Inst. Building Biol.+ Sustainability IBN, Rosenheim, Germany. SBM-2015.
2015.
19 Havas, M. (2014). Electrosmog and Electrosensitivity: What Doctors Need to Know to Help their Patients Heal. Anti-Aging
Therapeutics Volume XV. 20 Gomez-Perretta et al. Subjective symptoms related to GSM radiation from mobile phone base stations, BMJ, 2014 21 EUROPAEM Guideline 2015 for the prevention, diagnosis and treatment of EMF-related health problems and illnesses. Belyaev
I. Dean A. Eger H. Hubmann G. Jandrisovits R. et al. Rev Environ Health. 2015; 30(4):337-371.
22 Bhat, Kumar and Gupta. Effects of mobile phone and mobile phone tower radiations on human health. 2013
23 Park and Knudson. Medically Unexplained Physical Symptoms. Statistics Canada 2007 24 Johnansson O, Disturbances 2009
25 WHO, Electromagnetic Fields and Public Health, December 2005
126
hardware implants such Harrington rods, braces, wire meshes, pins and screws can potentially be affected.
Those with excessive gadolinium from multiple contrast studies are also at risk. Other toxic metals
include nickel (jewelry, cookware), lead (old water pipes), cadmium (smokers), aluminum(soy products,
contaminated water, medications) and arsenic (rice, fish, almonds, well water), all of which increase total
load. First Nations populations are at high risk given exposure to contaminated fish with methylmercury.
Patients present with headaches (lancinating and heaviness), brain fog, fatigue and anxiety when exposed
to EMFs.

Category II
Patients fall into this category if they suffer from infectious diseases such as Lyme disease, co-infections
of Lyme, and other infections which affect the nervous system. These patients have central or peripheral
nervous system vulnerability, neuroborreliosis, cerebral vasculitis, polyneuropathy, chronic
encephalomyelitis and cranial neuropathy (all late manifestations of Lyme). They present with tremor,
dysarthria, ataxia, extreme fatigue, headache, cognitive dysfunction, presyncope and mood disturbances.
It is important to reduce body burden through detoxification in order to decrease inflammation. Oxygen
therapy is useful in order to help with hypoxia from compromised cerebral blood flow to the bi-frontal
cortices and temporal lobes, but provides only short, temporary relief. This may help to confirm the
diagnosis, however. fMRI, SPECT, and PET scans can help further reveal pathology. Treatment of Lyme
with antibiotics can potentially decrease EHS symptoms.26

Category III
This category of patients suffer from lesions of the brain (including tumours such as pituitary adenomas),
demyelination, microangiopathic changes, diffuse ischemia, inflammation (from neurotoxic pesticides)
and neurodegenerative diseases (multiple sclerosis and ALS for example).27 Nonspecific white matter
findings due to simple aging and dementia should also be considered. They present with headaches, brain
fog, fatigue, restlessness and low mood, tinnitus(+/-) and potentiation of their already pre-existing signs
and symptoms related to their disease. The mechanism of action is associated with the impact of EMFs on
voltage gated calcium channel (VGCC) integrity, causing increases in intracellular calcium and thus
increase of oxidative stress from ONOO- formation.28

Category IV
These patient suffer from heart rhythm disturbances: either exacerbations of existing conditions or new
onset caused by radio and microwaves.29 There are periods of poor blood circulation at the capillary level
due to rouleaux formation and there is a disturbance of heart conduction because of effects on VGCC.
Tachycardic spells, especially at night, can occur. People also experience premature ventricular
contractions, premature atrial contractions, atrial flutter and fibrillation. Those with Wolff Parkinson
White syndrome are especially at risk for sudden cardiac death due to EMF exposures.30 Conduction
problems also affect the autonomic nervous system, causing increased sympathetic tone. A Holter monitor
will show rhythm disturbances near cellphone towers and in areas with high Wi-Fi usage. These
symptoms are very alarming to the patient and causes severe, prolonged anxiety. Sleep time can be also
particularly difficult causing frequent awakenings due to hyper-vigilance with tachycardic spells or PAC/
PVCs.

26 Belpomme, Dominique, Philippe Irigaray. “Electrohypersensitivity as a Newly Identified and Characterized Neurologic
Pathological Disorder: How to Diagnose, Treat, and Prevent It” Int. J. Mol. Sci. 2020; 21,1915.
27 De Luca C, Thai JC, Raskovic D, et al. Metabolic and genetic screening of electromagnetic hypersensitive subjects as a feasible
tool for diagnostics and intervention. Mediators Inflamm. 2014;2014:924184. doi:10.1155/2014/924184 28 Pall, Martin L. “Wi-Fi Is an Important Threat to Human Health.” Environmental Research 164 (July 1, 2018): 405–
16. https://doi.org/10.1016/j.envres.2018.01.035
29 Havas M. Radiation from wireless technology affects the blood, the heart, and the autonomic nervous system. Reviews on
Environmental Health. 2013 Nov 1;28(2-3):75-84.
30 Reversed reciprocating paroxysmal tachycardia controlled by guanethidine in a case of Wolff-Parkinson-White syndrome. Harris
WE. Semler HJ. Griswold HE. American heart journal 67.6 (1964): 812-816.
127
Category V
These patients include students and teachers. University, college, high school, and grade school students
are all being exposed to high levels of radiation. They frequently work under fluorescent lights. They get
eye strain, and sometimes develop rashes related to exposure of this radiation. The epidemic of anxiety,
depression, and suicide at universities and colleges is in part being fuelled by the increased level of
agitation and anxiety caused by radio and microwave radiation on mood. Students have extremely high
levels of nighttime exposure to RFR or electric fields/ dirty electricity. Before prescribing
methylphenidate or amphetamines, reducing EMFs in the workspace is critical.

Category VI
A minority of patients, approximately 1%, exhibit a nocebo response in which inert substances or mere
suggestions of substances actually bring about negative effects, i.e. feelings of malaise and anxiety. This
is understandable, given the ubiquitous nature of electrical devices in our everyday lives which is
unnatural. These patients tend to feel better using wearable jewellery, stickers on cellphones, and special
rocks (shungite).

Category VII
There are many clinical similarities and overlapping comorbid conditions between EHS and multiple
chemical sensitivities (MCS) that are reflected in similar genetic polymorphism profiles. Inflammation
resulting from impaired detoxification biochemical processes create illness and functional impairment.31
32

Physical Examination

Do a complete physical looking for dental amalgam load, metal appliances in the mouth, rashes on the
face and/or hands, signs of inflammation and edema, arrhythmias, autoimmunity. Abdomen may be tender
due to peristaltic abnormalities and bacterial dysbiosis. Usually a physical exam will reveal neurological,
dermatological and/or cardiac signs in the way of arrhythmia and/or poor circulation. Tremor of the
tongue and hands may be indicative of mercury overload.

There is no gold standard for EHS diagnosis except for elimination of the source and reintroduction/
provocation to confirm if the signs and symptoms are reproduced.

Laboratory and Diagnostic Tests

Studies have shown that approximately 30% of patients with EHS have no abnormal laboratory
biomarkers,33 but genetic polymorphisms are likely prevalent and need further investigation. Some blood
tests are expensive and not sensitive or specific but can help guide management if deficiencies or other
disease states exist that must be corrected.34 The following laboratory tests will help shed light on the total
toxic load and detoxification profile, and it is the combination that allows for the best management of the
patient:
• Essential mineral and toxic metal panel (RBC)
• GGT
• Bilirubin
• ALP
• Chromogranin A
31 De Luca C, Thai JC, Raskovic D, et al. Metabolic and genetic screening of electromagnetic hypersensitive subjects as a feasible
tool for diagnostics and intervention. Mediators Inflamm. 2014;2014:924184. doi:10.1155/2014/924184 32 Belpomme, Dominique, Christine Campagnac, and Philippe Irigaray. "Reliable disease biomarkers characterizing and identifying
electrohypersensitivity and multiple chemical sensitivity as two etiopathogenic aspects of a unique pathological disorder." Reviews
on environmental health 30.4 (2015): 251-271.
33 Belpomme D, Irigaray P. Electrohypersensitivity as a Newly Identified and Characterized Neurologic Pathological Disorder: How
to Diagnose, Treat, and Prevent It. International Journal of Molecular Sciences. 2020 Jan;21(6):1915.
34 Europaem 2015/ Oberfeld, 2016/ Belpomme, 2015
128
• Tryptase.35
• Vitamin D2-D3
• IgE, IgG, IgM, IgA
• Inflammatory markers (ESR, hsCRP, CRP, interleukins)
• Histamine
• Autoimmune markers (including thyroid antibodies)
• Presence of infectious diseases – screen for Lyme and co-infections (ELISA and Western blot)
• Mitochondriopathy (intracellular ATP)
• Oxidative stress lipid peroxidation markers
• Anti-myelin-O antibodies
• Nitrotyrosin (NTT) - Nitric oxide production increasing BBB permeability
• Melatonin (hydroxy-melatonin sulfate – 6-OHMS)
• SPEP – effects on bone marrow
• Salivary cortisol
• Alpha-amylase
• Transthyretin
• Blood sugar levels after provocation

Figure 2: (Belpomme et al., 2015)

To further aid in diagnosis:36
• Genetic testing to determine SNPs related to detoxification37
• Weighted MRI showing hypoperfusion in limbic system and thalamus
• Ultrasonic cerebral tomosphygmography (UCTS) and Transcranial Doppler US (TDU)38
showing temporal lobe hypoperfusion due to decreased flow in the middle cerebral artery
35 Belpomme, et al, 2015
36 Havas, 2010
37 The DNA Company. https://www.thednacompany.com/ 38 Belpomme, Dominique, Philippe Irigaray. “Electrohypersensitivity as a Newly Identified and Characterized Neurologic
Pathological Disorder: How to Diagnose, Treat, and Prevent It” Int. J. Mol. Sci. 2020; 21,1915.
129
Biomarker
High-sensitivity C reactive protein (hs-CRP)
Vitamin 02-03
Histamine
lgE
Protein S100B
Nitrotyrosine (NTT)
Heat shock protein 70 (HSP70)
Heat shock protein 27 (HSP27)
Anti-0-myelin autoantibodies
Hydroxy-melatonin sulfate (6-0HMS)
6-0HMS/creatinine
Normal range
$ 3 mg/L
~ 30 ng/ml
$10 nmol/L
$100 Ul/ml
$ 0.105 µg/L
~ 0.6 µg/L and$ 0.9 µg/ml
$ 5 ng/mL
$ 5 ng/ml
Negative
~ 5 ng/L and$ 40 ng/L
~ 0.8 and$ 8
• BP and heart rhythm monitoring for 24 hours (night-time changes) for heart rate variability and
heart rate abnormalities39
• Sleep study showing abnormalities due to wireless technology in the sleep labs. Alpha wave
intrusions and reduced REM sleep are the most likely finding.40

Co-Morbid Conditions

1. Toxic metal overload – mercury
2. Infectious diseases causing neural inflammation – e.g. Lyme disease
3. Toxic Mold Syndrome
4. Cardiac conduction abnormalities – PVC, PAC, atrial fibrillation
5. Neurodegenerative diseases
6. Multiple chemical Sensitivities (MCS)

Management

Allopathic
All co-morbid conditions need to be investigated further and treated. Referrals to specialists may be
required to address medial issues that may have been overlooked.

Pharmacological
Sleep restoration is paramount, and pharmaceuticals can be used if natural remedies are not effective.
Antihistamines with sedative effects are the drug of choice. For heart palpitations and arrhythmias,
especially those occurring at night, bisoprolol 1.25-2.5mg QHS helps. For sudden tachycardic spells,
waves of anxiety, and sympathetic overdrive, propranolol 2.5-5mg po QID PRN is also helpful.
Acetylsalicylic acid 81mg daily prevents coagulation secondary to high intensity effects due to the close
proximity of routers, DECT base stations and other potent emitters and combinations thereof. A calcium
channel blocker, such as diltiazem 15-30mg daily PRN, could help reduce symptoms. Gentle chelation
therapy may be required if toxic metal load is too high41.

Remediation
Health-care providers need to encourage patients to seek help from building biologists. These technicians
can assess the degree of EMF exposure a person is receiving in their home and make sensible
recommendations. The impacts of cell phone towers, smart meters and hydro wires on living spaces can
be determined, as well as anything internally generating EMFs. Voltage, power density and magnetic
fields, as well as dirty electricity can be measured. Proximity to wind turbines which, due to poor
enforcement of safety standards, emit ground currents that increase symptoms of EHS, can be identified.

Advise patients to use only corded phones without any electronic features. DECT cordless phones emit
RFR and need to be removed altogether.

Metallic paint on interior or exterior walls can be used to reflect radiation coming in from neighbours, cell
towers or other emitting devices. Any other type of shielding using metallic reflective surfaces can help
attenuate the signals.

Advise patients to turn off all wireless devices in the home and replace with ethernet cables or hardwire
everything were possible. Smartmeter removal or shielding installed by a technician is recommended.
39 Havas M. Radiation from wireless technology affects the blood, the heart, and the autonomic nervous system. Reviews on
Environmental Health. 2013 Nov 1;28(2-3):75-84.
40 Andrianome S, Hugueville L, de Seze R, Hanot‐Roy M, Blazy K, Gamez C, Selmaoui B. Disturbed sleep in individuals with
idiopathic environmental intolerance attributed to electromagnetic fields (IEI‐EMF): Melatonin assessment as a biological marker.
Bioelectromagnetics. 2016 Apr;37(3):175-82. 41 Sears ME. Chelation: harnessing and enhancing heavy metal detoxification—a review. The Scientific World Journal. 2013 Jan
1;2013.
130

Integrative
A diet rich in antioxidants and low in pro-inflammatory foods is strongly recommended. Eat organic if
possible. Omega-3 (balanced DHA:EPA 1:1) 1500mg daily will help with inflammation and neural
health. Vitamin D3 is also neuroprotective and should be taken at a dose of at least 4000IU per day.

Electrolytic imbalances for whatever reason (i.e. low K+, Na+, Cl-, etc.) need to be corrected with oral
rehydration solutions. To manage adrenal fatigue, adaptogen herbs and mindfulness based stress
reduction (MBSR) can be useful. Homeopathic treatments are useful for those with chemical sensitivities.

Enhance Natural Detoxification to Reduce Body Burden
• Natural detoxification strategies include: sauna therapies (depuration), MBSR, balanced diet,
supplements, exercise.
• To decrease body burden of oxidative stress (peroxynitrite ONOO-) or methylmercury take
antioxidants: vitamins E and C, glutathione, alpha-lipoic acid, N-acetyl-cystine, B vitamin
complex, zinc, resveratrol, CoQ10, selenium, turmeric. A high fibre diet (especially in the form
of bran) will assist with elimination of methylmercury.
• Correct any dental work with toxic or immunoreactive materials such as mercury, lead oxide,
gold or titanium and replace with zirconium dioxide, porcelain or composite.
• Mercury amalgams (mercury (50%), silver (~22–32%), tin (~14%), copper (~8%)) need to be
removed using proper protocol. 42 43

Fasting is not recommended due to the possibility of already existing poor nutritional status thus
inadequate supplies of vitamins, minerals and other antioxidant substrates in their body.44 Food
sensitivities/intolerances must be addressed.

Lifestyle
Tell patients to hold the cell phone away from their heads when in use and keep it in airplane mode when
not in use. The Bluetooth, data and Wi-Fi functions should be off if they are not being used. Extended
videogaming and high electronic equipment use can exacerbate symptoms and must be curtailed. Laptop
use in wireless mode needs to be switched to ethernet cable connectivity to decrease exposure.

Clothing (including the lining of hats) made of cotton fabric with copper or silver weave provides relief
during travel at airports, in hotels, etc., when shielding the torso and head. This can reduce palpitations
and headaches. Blankets/sheets with similar construction can be used to block out in-coming radiation
into habitable spaces during travel or at work.

A Faraday cage (canopy) can be used at night to reduce radiation on the body which can seriously
interfere with sleep quality. For sleep, herbal remedies and supplements are helpful. Magnesium
bisglycinate 100mg po QHS, increasing by 100mg weekly to bowel tolerance, can help with palpitations
and shock sensations.

Grounding practices are important to balance out the electron shifts. This should not be done under hydro
wires, where magnetic fields are extraordinarily strong. There will be a depletion of electrons. The aim is
to replenish lost electrons. Therefore, placing one’s bare feet on a special grounding mat, walking
barefoot on grass and sand or in lake shallows, pools or a bath tub can help. Grounding can be important
to balance out the electrons and replenish the electrons that have been depleted from the body.

Airpods and other wireless earpieces should not be used due to the proximity and intensity of the
radiation to the brain.
42 De Luca, 2014 43 Institute for Functional Medicine. Textbook of Functional Medicine. 2010.
44 Institute for Functional Medicine. Textbook of Functional Medicine. 2010.
131

Remove all harmful substances used in personal care products, cleaning and other household products, as
well as unnecessary medications.

Psychological
Finally, patients need a lot of psychosocial support in dealing with and removing stress triggers.
Mindfulness Based Stress Reduction, and CBT can be useful to decrease sympathetic nervous system
overdrive.

Connecting with support groups such C4ST, EPIC, WEEP and Electrosensitive Society, all of which are
Canadian based, can decrease social isolation.

Advocacy for Public Health Protection

• Accommodation at work, school or any learning institution should be supported thereby
respecting a person’s right to work and live in a space that is free of any potentially harmful
EMF exposure impacting on their biopsychosocialspiritual well-being.
• Students should be given letters/notes informing teachers of the need to be at a maximal distance
from routers and that laptops need ethernet access.
• People must be able to exercise their rights to refuse harm from EMFs which may be impacting
them, their children and loved ones or their fetus/embryo, if that be the situation. Each person,
should know exactly how much and what sort of radiation is impacting on their bodies.45 46
• Recommendations presented in the HESA report to the House of Commons – Radiofrequency
Electromagnetic Radiation and the Health of Canadians, 2010 and 2015 – can be used for
guidance in community events.
• Ontario wide, mandatory physician surveys, of how many patients they see in their roster who
complain of possible EMF-related signs and symptoms, should be implemented.
• Validated screening tools need to be developed through further research studies.
• Physician education through CME is critical.

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135
SCIENTISTS STATEMENT
136
IN THE SUPREME COURT OF PENNSYLVANIA
MIDDLE DISTRICT
RE: No. 34 MAP 2021, Povacz, M, et al. v. PUC
Associated Case(s):
35 MAP 2021 Consolidated
36 MAP 2021 Consolidated
37 MAP 2021 Consolidated
38 MAP 2021 Consolidated
39 MAP 2021 Consolidated
40 MAP 2021 Consolidated
41 MAP 2021 Consolidated
42 MAP 2021 Consolidated
43 MAP 2021 Consolidated
44 MAP 2021 Consolidated
45 MAP 2021 Consolidated

SCIENTISTS’ STATEMENT
RF/EMF & SMART METERS HARM
THE EFFECTS OF PULSED RADIOFREQUENCY AND
ELECTROMAGNETIC RADIATION EMISSIONS OF SMART METERS;
ESPECIALLY AS IT PERTAINS TO THOSE ADVERSELY AFFECTED

General Statement
We, the undersigned scientists, have cumulatively published hundreds of
peer-reviewed papers on biological effects of pulsed electromagnetic fields (EMFs)
and radiofrequency (RF) radiation and reviewed thousands more. For all of us the
study of the effects of pulsed RF/EMFs is one of our main areas of study; for some,
it is the main one. (A short bio for each of the undersigned is attached.)
137
We are filing this statement to clarify the state of the current science
regarding RF/EMF-based wireless technology adverse health effect and to explain
why smart meters can be harmful, at least to some people. Pulsed RF/EMF-based
wireless technology harms are not hypothetical. They are scientifically established,
and a significant number of people have already been seriously injured. Therefore,
we cannot stand by and allow the science to be misrepresented, especially in a case
of such importance involving public safety, where lives are at stake, the harms are
irreparable, and people are injured and could die.
RF Basics
1. Wireless technology uses electromagnetic waves to carry
information.1 A wave “frequency” is the number of wave cycles per second. Each
cycle per second equals a “Hertz” (“Hz”).2 Example: A 60 Hz frequency used for
home electricity has 60 wave cycles per second. The smart meter antenna that
1 An electromagnetic field (EMF”) is created by electric and magnetic components
emitted by moving charges and propagated through “waves” at the speed of light.
The interaction between the electric and magnetic fields “radiates” energy
(“radiation”). The electromagnetic spectrum is divided into classes: Extremely
Low Frequencies (ELFs), radio frequencies (microwaves are a subgroup of RFs),
infrared, visible light, ultraviolet, X-rays and gamma rays. RFs have a wave-cycle
between 3 kilohertz and 300 gigahertz
2 1,000 Hz is a kilohertz (“KHz”). 1,000,000 Hz is a megahertz (“MHz”).
1,000,000,000 Hz is a gigahertz (“GHz”).
138
transmits the usage data uses frequencies around 900 MHz, or about 900 million
wave cycles per second.
2. The Radio-Frequency (“RF”) “signal” is the “carrier wave.” But
communications require carrier wave manipulation to “encode” the data. Two main
techniques are used: “pulsation” and “modulation.” Modulation places additional
“mini”-waves on the RF. Pulsation injects “bursts” or turns the signal on/off.
Different technologies have their own protocols or “code.” Two devices using the
same code can “communicate” and exchange information.
3. Smart meters operate in the same way. They contain an RF antenna
that wirelessly transmits the usage data to the utility company. The antenna’s
carrier wave is around 900 MHz, but the data usage is transferred by modulating
the carrier wave. Furthermore, the communications occur every few seconds, so
the transmissions alternate between “silent” and “active.” This leads to an intensely
pulsed signal that has a jarring “on/off” effect on the body.
4. RFs emit “non-ionizing” radiation. Non-ionizing radiation does not
have sufficient energy to directly pull electrons from atoms and molecules to create
“ionization.” The FCC guidelines assume that non-ionizing radiation is not
harmful, unless it has high intensity power that causes tissue to heat as it absorbs
the radiated energy. This is called the “thermal effect.” The FCC’s regulations
139
acknowledge only thermal effects. Considering many thousands of studies have
proven non-thermal effects, this assumption cannot be defended.
CHD v. FCC and FCC Admission of Harm
5. On August 13, 2021, in a case amici Children’s Health Defense
brought against the FCC, the US Court of Appeals for the DC Circuit ruled that the
FCC failed to adequately consider and address the scientific and medical evidence
showing that its 1996 thermally-based guidelines do not sufficiently protect the
public. The Court held the FCC did not fully consider non-thermal harms other
than cancer effects, and as a result failed to engage in reasoned decision making.3
6. The FCC will have a hard time sticking to its current “no non-thermal
harm” construct on remand since it recently admitted there are neurological harms
from RF exposures, at least in the range between 3 Hz and 10 MHz.4 The FCC
noted “[a]dverse neural stimulation effects …such as perception of tingling, shock,
pain, or altered behavior due to excitation of tissue in the body’s peripheral
nervous system.” It also admitted that these harms occur instantaneously, which
3 Envtl. Health Tr., et al v. FCC, Nos. 20-1025, 20-1138, 2021 U.S. App. LEXIS
24138 (D.C. Cir. Aug. 13, 2021).
4 Proposed Changes in the Commission’s Rule Regarding Human Exposure to
Radiofrequency Electromagnetic Fields; Reassessment of Federal Communication
Commission Radiofrequency Exposure Limits and Policies, ¶¶122-124 & nn. 322-
335, 34 FCC Rcd 11687, 11743-11745 (2019).
140
means the FCC’s current method of averaging exposure levels over 30 minutes –
which completely obscures pulsation effects – is entirely inappropriate.5
The Scientific Consensus of Non-Thermal Harms
7. Some of the scientists who signed below published the evidence
presented in the DC Circuit court case, including the BioInitiative Report
(BioInitiative).6 The Bioinitiative is the most comprehensive scientific review on
the biological and health effects of Electromagnetic Fields (EMF) and RF-based
wireless technology by independent scientists (those with no conflict of interests).
The Bioinitiative concluded that bioeffects are established and can occur within
minutes of exposure to even very low levels of RF, including those emitted by
smart meters. With chronic exposures the biological effects can become adverse
effects and result in illness.7
8. Humans are bioelectrical beings. Our bodies use internally-generated
non-thermal EMFs to function. Our physiology is dependent on very sensitive
bioelectric systems, especially the heart, brain, nervous system, and intercellular
5 The Engineer’s Report attached to the amicus brief reveals that smart meters
pulse RF frequencies within this range (3 kHz – 50 KHz). The utility’s evidence
below relied in part on the FCC’s 30-minute averaging as the basis to deny any
negative pulsation effects.
6 https://bioinitiative.org/participants/.
7 https://bioinitiative.org/conclusions/.
141
communication.8 As the FCC stated in its admission, externally generated EMF
interferes with humans’ internal electrical communications system, and evokes
internal biological responses. These responses have nothing to do with power level
or tissue heating. The direct effect of pulsed RF/EMFs on humans’ physiology are
indisputable.
9. A 2011 National Institutes of Health (“NIH”) study9 is sufficient by
itself to destroy any denial of RF biological effects. Brain scans of 47 human
participants revealed that pulsed non-thermal RF radiation induced biological brain
glucose metabolism changes in every subject. See image below.

8 https://childrenshealthdefense.org/wp-content/uploads/rf-martin-blank.pdf.
9 https://pubmed.ncbi.nlm.nih.gov/21343580/.
142
0 60
10. Denial of biological effects of RF/EMFs cannot co-exist with the fact
that physicians routinely use FDA-approved, non-thermal pulsed EMF devices to
treat diseases, bone fractures10 and chronic pain,11 or that RF/EMF is used to treat
cancer.12
11. The only question is whether the biological responses can be adverse.
Numerous studies show indisputable evidence of adverse responses to pulsed
RF/EMF exposure on various bodily functions, especially when the RF exposure is
chronic and pulsed (like the exposure to smart meters).
12. Biological and even positive effects can become adverse effects. RF
signals affect living tissue and stimulate biochemical and bioelectrical changes,
which can generate biological effects which then, with chronic exposure, can
become adverse effects and cause various symptoms and may lead to sickness.13 A
good example of this mixed effect comes from the immune system: “short-term
exposure… may temporarily stimulate certain humoral or cellular immune
functions, while prolonged irradiation inhibits the same functions.”14
10 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3441225/.
11 https://www.accessdata.fda.gov/cdrh_docs/pdf19/K190251.pdf “the application
of electromagnetic energy to non-thermally treat pain.”
12 https://childrenshealthdefense.org/wp-content/uploads/rf-medical-treat-
cancer.pdf.
13https://bioinitiative.org/conclusions/.
14 https://www.sciencedirect.com/science/article/abs/pii/S0048969713003276.
143
Scientific Consensus
13. Numerous scientists,15 doctors, and medical and scientific
organizations from the US and around the world have warned of the negative non-
thermal effects of RF/EMF and the growing sickness it has been causing. They
include the EMF Scientist organization (250 scientists who combined published
over 2,000 peer-reviewed papers on the effects of RF/EMF);16 the American
Academy of Pediatrics; 17 the Austrian Medical Association;18 and doctors’ appeals
from the US;19 Belgium;20 and Germany.21 In 2021, close to 200 physicians
participated in a medical conference about RF/EMF effects, for which they
received medical continuing education credits.22
15 https://childrenshealthdefense.org/wp-content/uploads/rf-2017-expert-letters-
compilation.pdf.
16https://www.emfscientist.org;https://ecfsapi.fcc.gov/file/10916233196437/Interna
tional_EMF_Scientist-Appeal%208-25-2019.pdf.
17 https://childrenshealthdefense.org/wp-content/uploads/rf-2013-american-
academy-of-pediatrics.pdf.
18 https://childrenshealthdefense.org/wp-content/uploads/rf-2011-austrian-medical-
association-guidelines.pdf.
19 Baby Safe Project: https://www.babysafeproject.org/joint-statement.
20 Appeal of 539 Belgium Doctors: https://en.hippocrates-electrosmog-
appeal.be/medical.
21 Appeal of 1,000 German doctors http://freiburger-appell-
2012.info/media/International_Doctors_Appeal_2012_Nov.pdf.
22 https://emfconference2021.com/faculty/.
144
14. A California Medical Association resolution23 concludes that the peer-
reviewed research demonstrates wireless RF/EMF adverse effects, including
“single and double stranded DNA breaks, creation of reactive oxygen species,
immune dysfunction, cognitive processing effects, stress protein synthesis in the
brain, altered brain development, sleep and memory disturbances, ADHD,
abnormal behavior, sperm dysfunction, and brain tumors.”
15. Causal mechanisms of harms have been established. Oxidative Stress
is one such mechanism. Over 90% of studies on RF and oxidative stress24, 25 have
established that indeed exposure to RF/EMFs induces an increase in free radicals,
and chronic exposure causes oxidative stress which leads to several adverse health
effects: disease, dysfunction, including electro-sensitivity, cancer, and DNA
damage.
16. Even though RF does not have the energy to directly break chemical
bonds (the way ionizing radiation does), there is strong scientific evidence that this
energy can indirectly cause DNA damage.26 Dr. Ron Melnick PhD, a retired
23 https://childrenshealthdefense.org/wp-content/uploads/rf-2014-ca-medical-
association-resolution.pdf.
24 https://bioinitiative.org/wp-content/uploads/2020/09/3-RFR-Free-Radical-
Oxidative-Damage-Abstracts-2020.pdf.
25 https://childrenshealthdefense.org/wp-content/uploads/rf-2015-yakymenko-
oxidative-stress.pdf.
26 https://bioinitiative.org/wp-content/uploads/2020/09/10.-Comet-Assay-Studies-
Percent-Comparison-2020.pdf.
145
National Institute of Environmental Health Science (NIEHS) scientist, was the
Senior Toxicologist and Director of Special Programs in the National Toxicology
Program (NTP).27 He stated that the old notion that non-ionizing RF cannot break
DNA “should [be] put to rest.”28
17. Many thousands of studies, including US government and military
studies and reports, show the biological and adverse effects of pulsed RF/EMFs.29
In 2014 the US Department of Interior concluded that the FCC’s thermally-based
guidelines are “nearly 30 years out of date and inapplicable today.”30
18. The clear majority of studies show adverse effects.31 For example, 244
of the 335 total studies (73%) published on neurological effects of RF Radiation
between 2007 and 2020 found effects.32 Of the 261 total studies on RF radiation
27 https://emfconference2021.com/speaker/ronald-l-melnick-phd/.
28 https://microwavenews.com/news-center/ntp-comet-assay.
29 Navy report includes 2,300 studies. Pages 10-14 list the RF effects found.
https://childrenshealthdefense.org/wp-content/uploads/rf-1971-navy-2300-
studies.pdf; Air-Force: https://electroplague.files.wordpress.com/2014/09/rf-
microwave-radiation-biological-effects-rome-labs.pdf; NASA
https://www.orsaa.org/uploads/6/7/7/9/67791943/_____nasa_emf_field_interaction
s_-_observed_effects___theories_1981.pdf.
30https://drive.google.com/file/d/1XqbMLFUkVNUZIB5AFJAjr6KWqL6vK8ud/vi
ew.
31 https://bioinitiative.org/research-summaries/.
32 https://bioinitiative.org/wp-content/uploads/2020/10/13-Neurological-Effects-
Studies-Percent-Comparison-2020.pdf.
146
and oxidative stress, 240 (91%) show effects.33 224 of 346 total studies (65%)
show DNA damage. See image below.34, 35

19. The evidence is getting even stronger. Since 2016, when the
evidentiary record in this case was generated, hundreds more published peer-
reviewed studies, including by the US government, have established RF/EMF
effects.36
33 https://bioinitiative.org/wp-content/uploads/2020/09/9.-Free-Radical-Studies-
Percent-Comparison-2020.pdf.
34 https://bioinitiative.org/wp-content/uploads/2020/09/11-Genetics-Percent-
Graphic-Sept-1-2020.pdf.
35 https://bioinitiative.org/wp-content/uploads/2020/09/10.-Comet-Assay-Studies-
Percent-Comparison-2020.pdf.
36Abstract of over 700 papers (positive and negative published 2016-2019)
https://childrenshealthdefense.org/wp-content/uploads/rf-jmm-2016-2019-
studies.pdf; US Government NTP DNA Study
https://onlinelibrary.wiley.com/doi/full/10.1002/em.22343.
147
Majority of Studies Show Non-Thermal Effects (2020)
■ No Effect ■ Effects
-..------~----------------------
-
1111
Oxidativ Stress DNA Neurological
20. For example, in 2021 the Swiss government expert advisory group on
electromagnetic fields and non-ionizing radiation, BERENIS,37 evaluated the
scientific literature on non-thermal RF/EMF.38 The committee published a
preliminary paper which concludes that exposure could cause or worsen several
chronic illnesses, and that children, the elderly and people with immune
deficiencies or diseases are especially at risk. It also acknowledged that oxidative
stress is the underlying causal mechanism of harm.
21. In 2019, the New-Hampshire (NH) legislature voted unanimously to
establish a committee to learn the effects of 5G and wireless radiation. The
committee included scientists, public representatives, and representatives of the
wireless industry (through CTIA, the wireless industry lobby association). After a
year of hearing experts on both sides and reviewing the science, in October 2020,
the committee’s report was published. It concluded that wireless radiation non-
thermal harms are established. The committee recognized Electro-sensitivity and
the right for accommodation of those who suffer and emphasized the need to
37 https://www.bafu.admin.ch/bafu/en/home/topics/electrosmog/newsletter-of-the-
swiss-expert-group-on-electromagnetic-fields-a/beratende-expertengruppe-nis-
berenis.html.
38https://childrenshealthdefense.org/wp-content/uploads/rf-swiss-berenis-2021-
report.pdf.
148
educate doctors. NH is the only state in the US that has conducted an independent
full-scale investigation as to the harms of these technologies.
22. Former senior experts from government agencies responsible for this
issue are also part of the consensus on non-thermal harms. In addition to Dr.
Melnick, they also include: Dr. Linda Birnbaum, the former director (2009-2019)
of the National Institute of Environmental and Health Sciences (NIEHS); 39 Dr.
Christopher Portier, 40 former director of the National Center for Environment
Health at the Centers for Disease Control and Prevention (CDC), who also carried
various senior positions in the NIEHS, including Associate Director of the
National Toxicology Program (NTP). He wrote: “Most scientists consider non-
thermal effects as well established;”41, Dr. Carl Blackman,42 a biophysicist who
worked as a research scientist for the EPA from 1970 until his recent retirement.
Dr. Blackman’s research on RF/EMF resulted in several discoveries including
39 https://childrenshealthdefense.org/wp-content/uploads/sandri-birnbaum-amicus-
motion-and-brief-correct-final-8-6-2020.pdf#page=20.
40 https://www.iarc.who.int/wp-content/uploads/2018/07/PORTIER_Bio.pdf;
https://pubmed.ncbi.nlm.nih.gov/27656641/.
41 https://childrenshealthdefense.org/wp-content/uploads/rf-2016-portier-
consensus.pdf#page=1.
42 http://www.icems.eu/docs/Bios_Blackman.pdf.
149
multiple pulsation effects43 and treatment using RF/EMF.44 He is part of the
BioInitiative Working Group and wrote the 2007 Report’s section on pulsation and
modulation;45 Dr. Alan Frey,46 a US navy funded scientist was the first to show
non-thermal auditory effects and blood-brain barrier leakage. His studies tie
pulsation to the aggravating effects of RF signals.
Electro-Sensitivity
23. Electro-sensitivity is the earliest reported and likely the most direct
manifestation of RF/EMF-induced sickness. The condition, described by the
appearance of mostly neurological symptoms caused by RF/EMF exposure, has
been documented in the scientific literature for many decades, including by many
US government and military studies and reports.47 Many hundreds of studies
43 https://www.emfanalysis.com/wp-content/uploads/2015/06/blackman-
modulation-2009.pdf.
44 https://pubmed.ncbi.nlm.nih.gov/28930547/.
45 https://bioinitiative.org/wp-
content/uploads/pdfs/sec15_2007_Modulation_Blackman.pdf.
46 https://www.cellphonetaskforce.org/the-work-of-allan-h-frey/.
47 https://childrenshealthdefense.org/rf-1971-navy-2300-studies/;
https://electroplague.files.wordpress.com/2014/09/rf-microwave-radiation-
biological-effects-rome-labs.pdf;
https://www.orsaa.org/uploads/6/7/7/9/67791943/_____nasa_emf_field_interaction
s_-_observed_effects___theories_1981.pdf.
150
confirm the neurological effects and other symptoms48 reported by those who
suffer from the condition, and they have identified a genetic predisposition.49
24. The understanding of etiology, mechanisms and underlying injuries
involved with this condition has significantly progressed since 2016. New
diagnosis guidelines by leading EMF scientists and medical doctors have been
developed and published 50,51 There are more known biomarkers for diagnosis.52
25. Professor Beatrice Golomb, MD PhD was to the first to show
compelling evidence in a 2018 paper that the “mystery illness” (aka “Havana
Syndrome”) suffered by some US diplomats in Cuba and China was likely caused
by pulsed RF/EMF.53 She concluded that the diplomats suffer from Electro-
sensitivity, which she refers to as Microwave Illness.54
48https://childrenshealthdefense.org/wp-content/uploads/rf-2018-neurological-lai-
book-chapter.pdf.
49 https://pubmed.ncbi.nlm.nih.gov/24812443/.
50 https://www.degruyter.com/document/doi/10.1515/reveh-2016-0011/html.
51https://www.womenscollegehospital.ca/assets/pdf/environmental/Preliminary%2
0Clinical%20Guidelines%20%20for%20EHS.pdf.
52 https://emf-experts.news/wp-content/uploads/2020/09/Belpomme-
EHSdiagnosis-Study2020.pdf.
53 https://pubmed.ncbi.nlm.nih.gov/30183509/.
54 “Microwave” is a subclass of RF, and generally comprises frequencies between
300 MHz and 300 GHz. From an FCC nomenclature perspective, the “microwave”
portion is anything above 890 MHz.
151
26. The US State Department asked the National Academy of Sciences,
Engineering and Medicine (NAS) to analyze and provide input on the diplomats’
“mystery illness.” Prof. Golomb was invited to present to the committee.55 In
December 2020, The NAS report was published. 56 It concluded that many of the
observed symptoms are consistent with the scientific literature on the effects of
pulsed RF exposure, and that it is likely the cause of the diplomats’ sickness.
27. Not all the diplomats became ill, only some, similar to Electro-
sensitivity in the general population. Human physiology varies, and as with other
stressors, some people get sick sooner than others or at lower levels of exposure
than others, and some will never become ill.
28. Prof. Golomb’s paper shows Electro-sensitivity can occur as the
byproduct of wireless technology, whether the result of an intentional assault
through a pulsed RF/EMF weapon or by commercial wireless technology. The
harm caused by these weapons comes primarily from the pulsation, not the
intensity of the RF/EMF. Indeed, it would be possible for RF/EMF weapons to
operate entirely within FCC guidelines and still cause harm from pulsation.
Pulsation is also a driver of the harm flowing from commercial RF/EMF-emitting
55 https://childrenshealthdefense.org/wp-content/uploads/rf-2018-golomb-
diplomats-3.pdf; https://childrenshealthdefense.org/wp-content/uploads/rf-nas-
golumb-email.pdf.
56 https://www.nap.edu/read/25889/chapter/1.
152
technology, including smart meters. Nevertheless, FCC rules regarding wireless
technology ignore their effects.
29. Electro-sensitivity is not a mere “sensitivity.” Studies have shown that
the symptoms indicate severe physiological injuries associated with exposure to
RF/EMF.57
30. A 2017 functional MRI study observed brain injury in persons with
Electro-sensitivity. 58 The scans for each of the 10 subjects had similar
abnormalities, all resembling those flowing from traumatic brain injury. The
diplomats had the same abnormalities. This injury indicates impaired blood flow in
certain regions of the brain.

57 https://pubmed.ncbi.nlm.nih.gov/26613326/.
58 https://pubmed.ncbi.nlm.nih.gov/28678737/.
153
Brain Differences In EHS compared to non-EHS
0--ffl'I fMRI of Adult, no (HS fMRI of Mull, with (HS
31. A 202059 and a 201560 papers confirm the blood flow effects and show
additional injuries. They are based on a study of 700 people with electro-sensitivity
showing the subjects suffered from permeability of the blood-brain barrier,
depressed melatonin levels, oxidative stress and aggravated auto-immune response.
These effects were shown to be connected to RF exposure61. In CHD’s case against
the FCC, the court specifically mentioned that the FCC failed to respond to the
evidence showing these effects.62
32. Those who want to propagate this technology have consistently
generated perceived “controversy” as a method to deny Electro-sensitivity. They
do so by funding negative subjective-perception provocation studies so they can
claim that it is psychological or fear-induced (the “nocebo effect”). These studies
suffer from numerous fatal design flaws.63
33. The most ironic design flaw in these studies is that they do not control
for the nocebo effect, which is a prerequisite to the validity of any provocation
59 https://emf-experts.news/wp-content/uploads/2020/09/Belpomme-
EHSdiagnosis-Study2020.pdf.
60 https://pubmed.ncbi.nlm.nih.gov/26613326/.
61 https://bioinitiative.org/wp-
content/uploads/pdfs/sec01_2012_summary_for_public.pdf#page=10;
https://bioinitiative.org/table-of-contents/.
62 Envtl. Health Tr. v. FCC, Nos. 20-1025, 20-1138, 2021 U.S. App. LEXIS 24138,
at *12-*16 (D.C. Cir. Aug. 13, 2021).
63 Many of those provocation studies were heavily funded by mobile phone carriers
and led by James Rubin PhD, a psychologist (not EMF expert).
154
study. Then they conclude that the symptoms are likely a result of a nocebo
effect.64
34. Another primary flaw in these studies is the illogical assumption that
all people with Electro-sensitivity should be able to immediately “detect” when the
RF signal is on/off. But those affected do not typically “sense” radiation. They
develop symptoms that take time to appear and subside. There are many other
flaws. Nevertheless, properly conducted studies without predetermined agenda
show that some sufferers can detect the signal.65
35. Subjective-perception provocation studies are considered the worst
science because they can be easily manipulated.66 Industry uses these studies to
produce the required results to divert attention from hundreds of high-quality peer-
reviewed credible studies that do not depend on subjective-perception and confirm
the symptoms people develop, the corresponding physiological injuries and
established causal mechanisms.67, 68
64 https://www.bmj.com/content/bmj/332/7546/886.full.pdf.
65 For example, a large scale study by the Dutch government, known as the TNO
study: https://childrenshealthdefense.org/wp-content/uploads/rf-electrosensitivity-
provocation-tno.pdf.
66 https://ecfsapi.fcc.gov/file/7520940903.pdf#page=25.
67 https://childrenshealthdefense.org/rf-2018-Golomb-Diplomats-2/#page=9.
68https://childrenshealthdefense.org/rf-2014-electrosensitivity-dr-blythe/.
155
36. It is important to emphasize that while widely quoted and used to
deny Electro- sensitivity, subjective-provocation studies are not used to diagnose
any condition and are definitely “not suitable to disprove causality.”69 A person’s
inability to detect the pathogen that causes the reaction does not mean the
individual is unaffected by the pathogen. “Human RF-detector” is not a mandatory
symptom for Electro-sensitivity.
Smart Meters’ Effects
37. Beyond individual predisposition, the appearance of adverse effects
can depend on signal intensity, exposure duration; specific frequencies involved;
exposure to multiple frequencies and sources which create high exposure
variability; on-off pulsation and sharp “peaks and valleys.”
38. Expert smart meter testing indicates there are three primary RF
exposure issues.70, 71, 72,73 First, the RF antennas within the meter send usage data
and communicate with other meters and smart devices. They wirelessly emit
69 https://childrenshealthdefense.org/wp-content/uploads/rf-2016-europaem-
guidelines.pdf #page=11.
70 https://childrenshealthdefense.org/wp-content/uploads/pa-amicus-sage-smart-
meters.pdf.
71 https://childrenshealthdefense.org/wp-content/uploads/rf-pa-amicus-engineer-
expert-erik-anderson-report.pdf.
72 https://childrenshealthdefense.org/wp-content/uploads/pa-amicus-isotrope.pdf.
73 https://childrenshealthdefense.org/wp-content/uploads/pa-amicus-bathgate-pa-
smart-meters.pdf.
156
intensely pulsed RF/EMF. Second, these antennas’ RF emissions also conduct over
the home electric wiring,74 transforming the entire house into a “repeater” antenna.
39. Finally, the switch mode power supply (SMPS) creates RF
frequencies as a byproduct of the AC/DC conversion process. The traditional
analog meters used for decades do not have SMPS and do not create these
emissions. SMPS-generated emissions are typically in the range of 2-150 KHz.
They enter the house’s electric wiring and then radiate RF in various parts of the
house. Digital meters also use SMPS; therefore, they too create RF frequencies,
even though they do not have transmitting RF antennas.
40. As noted, the FCC admitted there are neurological effects from non-
thermal RF emissions75 and its admission applies to frequencies in the kilohertz
range created by the SMPS. The symptoms the FCC recites are similar to those
reported by those who assert adverse effects from smart meters including tingling,
shock, pain, or altered behavior due to excitation of tissue in the body’s peripheral
nervous system.76 The FCC explained that the presence of these frequencies
outside the body induce “internal electric fields” within the human body.
74 https://childrenshealthdefense.org/wp-content/uploads/pa-amicus-isotrope.pdf.
75 Proposed Changes in the Commission’s Rule Regarding Human Exposure to
Radiofrequency Electromagnetic Fields; Reassessment of Federal Communication
Commission Radiofrequency Exposure Limits and Policies, ¶¶122-124 & nn. 322-
335, 34 FCC Rcd 11687, 11743-11745 (2019).
76 FN. 328, p.58.
157
41. A single smart meter antenna can emit up to 190,000 short but intense
RF pulses (bursts/spikes) each day to transmit the usage data to the utility. These
bursts can be two and a half times above the FCC’s limits, if you do not apply the
30-minute “averaging” used in the FCC testing. The D.C. Circuit questioned77 this
averaging and the FCC proposes to abandon it, at least in part.78 Depending on how
close the meter is to occupied space within a home, a smart meter can cause very
high intensity RF/EMF exposures.
42. People in proximity to a smart meter are at risk of significantly high
aggregate whole-body exposure to RF/EMF. This is especially true regarding
people living near multiple meters mounted together in an apartment complex or
those who have a utility collector meter installed on their home which relays RF
signals of up to 5,000 homes.79 The cumulative 24/7 exposure is never measured
but undoubtedly harmful, at least to some.
43. Studies have consistently shown that the pulsing is a major element in
the creation and/or aggravation of effects from RF exposure. It is possibly more
77 Envtl. Health Tr. v. FCC, Nos. 20-1025, 20-1138, 2021 U.S. App. LEXIS 24138,
at *12 (D.C. Cir. Aug. 13, 2021).
78 Proposed Changes in the Commission’s Rule Regarding Human Exposure to
Radiofrequency Electromagnetic Fields; Reassessment of Federal Communication
Commission Radiofrequency Exposure Limits and Policies, ¶¶122-124 & nn. 322-
335, 34 FCC Rcd 11687, 11743-11745 (2019).
79 https://childrenshealthdefense.org/pa-amicus-sage-smart-meters/#page=3.
158
important than the radiation levels.80 EMF-based medical treatments, for example,
recognize the higher bio-active nature of pulsation; they purposefully pulse the
signal to obtain a higher biological response.
44. The effects of continuous exposure and the on/off pulsation effects
were shown in a 2011 study.81 The study tested a physician with Electro-
sensitivity. She developed temporal pain, headache, muscle twitching, and skipped
heartbeats within 100 seconds after each signal exposure. The study showed that
the symptoms appeared in response to the on-off pulsing of the signal rather than
the presence of a continuous EMF field or its intensity. “EMF hypersensitivity can
occur as a bona fide environmentally inducible neurological syndrome.”
45. The energy emitted by the RF antennas and from the operation of the
SMPS enters the wiring system through “high variability” spikes in various RF
frequencies. This has an on/off effect on the body. Studies have shown that the
body is especially sensitive to “high variability” emissions.82

80 https://bioinitiative.org/wp-
content/uploads/pdfs/sec15_2007_Modulation_Blackman.pdf;
https://bioinitiative.org/wp-
content/uploads/pdfs/sec15_2012_Evidence_Disruption_Modulation.pdf.
81https://www.stopumts.nl/pdf/McCarty%20Marino%202011%20EMF%20ES%20
&%20neurological%20syndrome%20Int%20J%20Neurosci%20July.pdf.
82https://childrenshealthdefense.org/wp-content/uploads/rf-2015-Panagopoulos-
variability-effects.pdf.
159
Conclusion
46. Anyone who claims smart meters cannot produce the symptoms
described by the customers is ignorant of the FCC’s recent admission. They either
do not understand or are misrepresenting the science on biological and adverse
effects from pulsed RF/EMF. Many have reported getting ill following the
installation of these smart meters. Considering the way smart meters operate and
the multitude of complex emissions they create, it is no wonder. Forcing these
meters on people who have become affected by RF/EMF is unconscionable. Those
with Electro-sensitivity and others who are affected by RF/EMF must be allowed
to secure analog meters because it is the only type of meter that does not cause or
worsen their condition.

Respectfully Submitted,
Scientists Statement Signatories
Professor David O. Carpenter, MD, Professor of Environmental Health
Sciences, and Director, Institute for Health and the Environment at the
University of Albany, a collaborating center for the World Health Organization
(WHO). Dr. Carpenter is a Harvard trained public health expert who focuses on
the study of environmental causes of human disease with expertise in
electrophysiology, low-frequency electromagnetic field and radiofrequency
(RF) radiation bioeffects. He was Chairman of the Neurobiology Department of
160
Armed Forces Radiobiology Research Institute at the Defense Nuclear Agency
in Washington DC; the Director of Wadsworth Center for Laboratories and
Research of the New York State Department of Health; and Executive Secretary
of the NY State Power Line Project regarding health effects associated with
exposure to EMFs. After the project concluded, he became spokesperson for
NY state on all matters associated with EMFs. He is the Co-Editor of the
BioInitiative: A Rationale for a Biologically-based Public Exposure Standard
for Electromagnetic Fields. Dr. Carpenter has authored more than 400 scientific
papers.
Professor Igor Belyaev, DSc, Head, Department of Radiobiology; Cancer
Research Institute, Biomedical Research Center, Slovak Republic. He has an
MSc. Degree in Radiation Physics and Dosimetry; PhD in Radiobiology; and
DSc. degree in Genetics. He was an Associate Professor of Toxicological
Genetics at the Stockholm University, Sweden, as well as a senior research
scientist and group leader in the departments of Radiobiology, Molecular
Genome Research, Genetic and Cellular Toxicology, Genetics, Toxicology and
Microbiology. He is now or formerly a member of: The Working Group of the
International EMF Project of the World Health Organization; the Working
Group for the evaluation of RF carcinogenicity of the International Agency on
Research in Cancer (IARC); the Swedish National Committee for Radio-
Science; the Russian National Committee on Non-Ionizing Radiation
Protection; the EMF Working Group of the European Academy for
Environmental Medicine (EUROPAEM). He serves as Associate Editor for the
International Journal of Radiation Biology and on the Editorial Board of
Electromagnetic Biology and Medicine. He published over 100 scientific papers
and was awarded by the Bioelectromagnetics Society for the most influential
161
paper in Bioelectromagnetics 2006-2010. He is a member of the BioInitiative
Working Group and authored the BioInitiative’s 2012 Section on the effects of
Pulsation and Modulation.
Professor Beatrice Golomb, MD, PhD, Professor of Medicine at the
University of California, San Diego. She also leads a research group which
focuses on the relation of oxidative stress and mitochondrial function to health,
aging, behavior, illness, environmental and medication effects, nutrition, and
bioenergetics. She served as a primary care doctor of veteran patients for over
15 years. She is known for her work on Gulf War Illness, statins and placebos
and for her 2018 paper “Diplomats’ Mystery Illness and Pulsed
Radiofrequency/Microwave Radiation” which concludes, “Reported facts
appear consistent with pulsed RF/MW as the source of injury in affected
diplomats.” She was invited to present to the National Academy of Sciences
about these findings. She has published 136 scientific papers.
Professor Reba Goodman, PhD, Professor Emeritus in Clinical Pathology
at Columbia University. Dr. Goodman received an MA and a PhD in
Developmental Genetics from Columbia University. She has authored a great
many studies, including at least 76 studies on effects of electromagnetic fields.
Early on, in her paper in Science entitled “Pulsed electromagnetic fields induce
cellular transcription,” (1983), she showed how even weak, pulsing
electromagnetic fields could modify biological processes.
Professor Lennart Hardell, MD, PhD, is a retired Professor of Oncology
and Cancer Epidemiology, from Örebro University Hospital in Sweden. Dr.
Hardell continues his work through his involvement with the Environment and
Cancer Research Foundation. His research focus has been the environmental
162
risk factors for cancer. Prof. Hardell has been awarded several scientific prizes
for his research. In recent decades his research focused on the effects of RFR
exposure, especially on mobile phones and the risk of brain tumours. The
research by the Hardell group influenced IARC’s 2011 classification of
radiofrequency radiation as a possible 2B carcinogen. Dr. Hardell was also a
member of IARC’s evaluating group. He has published more than 350 peer-
reviewed scientific papers, including many on the biological effects of
electromagnetic radiation.
Professor Paul Héroux, PhD, Director of the Occupational Health Program,
Faculty of Medicine, McGill University, Canada. Dr. Heroux is a toxicologist
with a PhD in Physics. He teaches courses at McGill University about the
adverse health effects of EMFs. He has published 42 scientific papers, 27 of
them on the effects of EMFs. He also authored several text books. His most
recent paper is “Adverse health effects of 5G mobile networking technology
under real-life conditions.” (Toxicol. Let 2020). He is a member of the
BioInitiative Working Group and was a member of the committee appointed by
the New Hampshire legislature to review the effects of 5g and wireless
technologies.
Professor Olle Johansson, PhD, retired associate professor at the Karolinska
Institute, Department of Neuroscience, and head of The Experimental
Dermatology Unit from the Karolinska Institute, and the Royal Institute of
Technology, Stockholm, Sweden. He has published more than 800 papers,
conference reports, book chapters, commentaries, and debate articles. His main
focus was basic and applied neuroscience. Starting in 1977, his research
focused on the adverse health and biological effects of man-made pulsed RF-
163
based wireless technologies. He has published more than 330 papers in that
field, many with a focus on the effects on the skin.
Professor Anthony B. Miller, MD, CM, FRCP, FRCP(C), Professor Emeritus,
Dalla Lana School of Public Health, University of Toronto. He was the
Director, Epidemiology Unit, National Cancer Institute of Canada; Professor,
and Chair of the Department of Preventive Medicine and Biostatistics,
University of Toronto; Special Expert in the Division of Cancer Prevention, US
National Cancer Institute; Senior Epidemiologist, International Agency for
Research on Cancer; Head, Division of Epidemiology, German Cancer
Research Centre; Associate Director Research, Dalla Lana School of Public
Health, University of Toronto. In 2019 he was elected a Member of the Order
of Canada for his work on Cancer Control. He has published 354 peer-reviewed
papers. In the past few years he has focused on RF/EMF effects. He has
published six papers on the topic of RF/EMF and has presented in many
conferences on this issue.
Professor Martin Pall, PhD, Professor Emeritus of Biochemistry and Basic
Medical Sciences at Washington State University. Dr. Pall is a published and
widely cited scientist on the biological effects of electromagnetic fields and
speaks internationally on this topic. His expertise includes how RF/EMF
impacts the electrical systems in our bodies with a focus on the VGCC injury
mechanism. He published seven papers showing that pulsed RF/EMF interferes
with the operation of the voltage-gated calcium channel, a sensor that is
responsible for the entry of calcium into our cells.

164
Alfonso Balmori, BSc, M.S.Ed, is a world renowned biologist, with a
master in environmental education. He has published more than 50 scientific
papers published in peer-reviewed journals on environment, ecology, and
biodiversity conservation issues. He is known worldwide for his work on the
effects of electromagnetic RF radiation on animals and plants, mainly on the
effects of cell towers. His papers were quoted in the US Department of the
Interior 2014 letter concluding that cell towers harm migratory birds and that
the FCC guidelines are 30 years out of date. This letter was referenced by the
Court in the Remand Guidelines decision.
Professor Kent Chamberlin, PhD, Past Chair and Professor Emeritus,
Department of Electrical and Computer Engineering, University of New
Hampshire. The focus of his research has been Computational
Electromagnetics. He also investigated the interaction of electromagnetic fields
and the human body, which resulted in seven publications. He was appointed by
the Chancellor to the New Hampshire Commission to Study the Environmental
and Health Effects of Evolving 5G Technology, which concluded that 5G and
pulsed RF-based wireless technologies are harmful to health.
Dr. Priyanka Bandara, PhD, is a scientist with a PhD in Biochemistry and
Molecular Genetics. She served as senior manager of a research team and a
clinical team at Westmead Children’s Hospital, Australia. She then became
involved in environmental health and disease prevention. Her current focus is
the impact of pulsed RF-based wireless technologies on health. Dr. Bandara has
published 13 papers on the effects of electromagnetic radiation in international
scientific journals, and has presented at major conferences and academic
institutions. She serves as Associate Editor of the Journal of the Australasian
165
I
College of Nutritional and Environmental Medicine and as peer-reviewer for
several international medical journals.
Dr. Frédéric Greco, MD, is a practitioner in the neuro-intensive care unit at
the University Hospital of Montpellier, France, and teaches at the university’s
Faculty of Medicine. He is a member of the working group set up by the French
government's health department to implement national recommendations for the
medical care of electrosensitive people. He is the principal investigator of the
ongoing clinical study "Migraine in Electrohypersensitive Patients."
Dr. Yael Stein, MD, is head of the Electromagnetic Radiation Research Clinic
at Hadassah Medical Center, Jerusalem, Israel, focusing on electro-sensitivity
diagnosis and treatment. She is a certified Anesthesiologist at Hadassah
Medical Center and researcher at the Hebrew University Medical School. She
also specializes in Pain Medicine and is currently completing an MPH at the
Hebrew University School of Public Health. She has extensive experience in
research on the health effects of electromagnetic fields on humans from the
epidemiologic and biological/medical points of view, and has worked in this
field since 2007.
Cindy Sage, MA, is an environmental sciences consultant and researcher on
electromagnetic fields and radiofrequency radiation. She is the founder of the
international BioInitiative Working Group, and the co-editor of the BioInitiative
Reports (2007 and 2012). Ms. Sage has provided expert testimony and
scientific testimony on non-ionizing radiation to the Federal Communications
Commission, the US Food and Drug Administration, the California Public
Utility Commission, the European Commission’s Directorate of Public Health -
Scientific Committee on Emerging and Newly Identified Health Risks
166
(SCENIHR). She has advised numerous state and federal agencies on wireless
health risks, smart meter emissions and safety limit inadequacies. She has
published 24 peer-reviewed papers on the evidence of health risks from
electromagnetic fields and radiofrequency radiation, and she studies the effects
of smart meters.
Dr. Cindy Russell, MD, is a surgeon and Executive Director of Physicians
for Safe Technology. Since 1995, she has been a member of the Santa Clara
County Medical Association Environmental Health Committee. Dr. Russell has
published several peer-reviewed papers on the impacts of wireless technology
on human health and the environment with hundreds of scientific references.
Her focus continues to be disease prevention and environmental health through
toxics reduction.
Dr. Mary Redmayne, PhD, is a researcher, educator and consultant with
Adjunct Research Fellowships at Victoria University of Wellington and at
Monash University, Melbourne. Her research interests and experience include
children’s use of wireless devices and their effect on health and well-being.
She has many peer-reviewed papers, with at least 22 on health and
electromagnetic fields and RF radiation. She lectures on these issues both in
New Zealand and internationally. Dr. Redmayne is a Participating Member of
Standards Australia Committee on Human Exposure to Electromagnetic Fields,
a technical committee responsible for standards settings. She is a scientific
advisor for the Oceania Radiofrequency Scientific Advisory Association, and
for the Building Biology and Ecology Institute, NZ.

167
ENGINEER REPORT
168
IN THE SUPREME COURT OF PENNSYLVANIA
MIDDLE DISTRICT
RE: No. 34 MAP 2021, Povacz, M, et al. v. PUC
Associated Case(s):
35 MAP 2021 Consolidated
36 MAP 2021 Consolidated
37 MAP 2021 Consolidated
38 MAP 2021 Consolidated
39 MAP 2021 Consolidated
40 MAP 2021 Consolidated
41 MAP 2021 Consolidated
42 MAP 2021 Consolidated
43 MAP 2021 Consolidated
44 MAP 2021 Consolidated
45 MAP 2021 Consolidated

Engineer Report – Smart Meters Operation & RF Emissions

Purpose of Statement
1. My name is Erik S. Anderson, P.E. I am a forensic electrical engineer
working on root cause failure analysis of matters that cause loss of property,
personal injury, and loss of life.
2. I am submitting my expert opinion regarding the operation of smart
meters and digital meters and in support of the amici.
169
Credentials
3. I am the president of an engineering firm that offers professional
engineering and investigation services across the United States and manufactures
current transformers.83
4. It is my expert opinion that these smart and digital meters cause a
significant amount of radio-frequency (RF) “noise” on homes’ electric wiring
system, thereby transforming them into a whole house antenna.
5. I have a Bachelor’s of Science degree from North Dakota State
University, Fargo, North Dakota, in Electrical and Electronic Engineering. I am a
licensed Professional Engineer in the states of Minnesota, Illinois, Arizona,
Wisconsin, Indiana, Iowa, New Mexico, Texas, Louisiana, California, Kentucky,
Michigan, and Nevada. I am a licensed Class A Master Electrician in the state of
Minnesota. I also hold a Private Investigator License in Arizona and I am a
Certified Fire and Explosion Investigator.
6. I have 30 years of experience as a forensic engineer. I have over 20
years of experience of design and manufacture of current transformers. I have been
involved in many thousands of matters concerned with determining the root cause
of failures of electrical devices that may have caused a loss of property, personal
injury, or loss of life. I have given expert witness testimony in approximately 113
83 https://www.aenpi.com/
170
separate matters. I personally have tested smart meters and given expert testimony
regarding their operation and emissions. My curriculum vitae is attached (Exhibit
1).
7. As a designer and manufacturer of transformers, their operation is one
of my main areas of expertise. Switch Mode Power Supply modules used by smart
and digital meters are merely another type of transformers. I have investigated the
involvement of the operation of the Switch Mode Power Supply in these meters
and their involvement in the creation of radio frequency (RF) emissions.84
8. My expert determination principally relies on my own smart meter
testing. I do also rely on reviews by other experts, their’ testing reports and my
professional education and vast experience.
Smart Meter Operation
9. Smart meters create intense exposure to pulsed radio frequencies (RF)
in a few ways. RF antennas are embedded within the smart meter to transmit data
usage to utility companies and/or to communicate with other smart meters or with
other “smart” devices like home thermostats. These antennas emit pulsed RF
radiation. The various radiofrequencies emitted by these antennas also conduct
through the home electric wiring. RF “wire conducted” frequencies come also
84 An explanation of what are radio frequencies and about the electromagnetic
spectrum can be found in the scientists’ statements which is also attached to the amicus
brief as well as in the amicus brief itself.
171
from the conversion process from alternating current (AC) to direct current (DC)
handled by the Switch Mode Power Supply (SMPS).85 Non-transmitting digital
meters also use SMPS, and therefore they too create RF, even though they do not
contain a transmitting RF antenna for communications. These radio frequencies are
transmitted on the residence’s electrical distribution system and conduct over the
internal wiring, thereby turning the home into a whole-house antenna.
RF Emissions from the Transmitting Antennas
10. The RF antennas that wirelessly transmit the consumer’s electrical
power usage data to the utility company use frequencies in the 900 MHz & 2,400
MHz range. These emissions are intense and can occur often, up to 190,000 times a
day.86 From my experience and testing done by others, these meters transmit more
times than the electric companies report. This can easily be shown by measuring
the emissions with a simple RF meter.
11. “Isotrope Wireless,”87 which provides industry and municipalities
with design, specification, evaluation, and construction support for wireless
facilities, tested smart meters in three houses.88 This testing showed that RF
emission from the smart meters’ transmitting antennas could be detected
85 In some meters the conversion is done using capacitators instead of SMPS.
86 https://childrenshealthdefense.org/pa-amicus-sage-smart-meters/.
87 https://www.isotrope.im/about-2/.
88 https://childrenshealthdefense.org/pa-amicus-isotrope/.
172
throughout the house and were “well above” the ambient RF radiation levels.89
These pulsed RF emissions exceed the absolute energy output limits90 stated in
Federal Communications Commission (FCC) guidelines (if the emissions are not
averaged over a 30-minute exposure as prescribed by those guidelines).91
RF from Wireless Antennas Enter the House’s Electrical System
12. The Isotrope testing also showed that the house’s electrical wiring
conducted substantial levels of the RF emissions at 915 MHz – the
communications-related frequency for that meter92 – and this frequency was then
radiated from outlets (electrical power delivery points) and along the house wiring
(branch circuitry).
89https://childrenshealthdefense.org/pa-amicus-isotrope/#page=12.
90 https://childrenshealthdefense.org/pa-amicus-sage-smart-meters/#page=3.
91 On August 13, 2021, the Court of Appeals for the DC Circuit ruled that the FCC’s
2019 decision that its guidelines adequately protect the public’s health are arbitrary,
capricious and not evidence-based. The Children’s Health Defense is a Petitioner in
this case. Envtl. Health Tr., et al v. FCC, Nos. 20-1025, 20-1138, 2021 U.S. App. LEXIS
24138 (D.C. Cir. Aug. 13, 2021). The opinion specifically questioned whether the
FCC’s testing procedures adequately captured the effect of pulsation or modulation.
2021 U.S. App. LEXIS 24138, *12, *29.
92 Smart meters use a variety of frequencies for communications depending on the
manufacturer’s choice. PECO’s meters operate at around 901 MHz. They also contain
a “Zigbee” antenna that can be turned on and then communicate with nearby wireless
smart devices. Zigbee uses 2400 MHz band.
173
13. Thus, the pulsed RF emissions from the smart meter’s transmitting
antenna not only enter the house wirelessly but also enter into and are conducted
along the house’s electrical wiring
RF “Noise” From the Switch Mode Power Supply
14. Other RF frequencies besides the RFs from the transmitting antennas,
also enter the house electric system. In my testing I have witnessed and analyzed
smart meters’ effects on the incoming electrical power voltage waveform. These
frequencies are a byproduct of the AC/DC conversion process which is done by the
Switch Mode Power Supply (SMPS). The conversion process is necessary because
utility service employs alternating current whereas the electrical components in
smart meters use direct current.93
15. SMPS converts the 240 Volt AC power coming into the meter from
the main power transformer, into the much lower DC voltage that the electronic
devices require to function. The rapid back-and-forth conversion process used to
remove the “alternating” aspect creates unintended RF frequencies. The on/off,
back-and-forth, pulses can occur up to 150,000 times per second, which means
frequencies of up to 150,000 Hz (150 KHz94), are created. These kilohertz
93 Smart meters also rely on AC for some of the non-electronic functions they
perform.
94 1,000 Hz is a kilohertz (“KHz”). 1,000,000 Hz is a megahertz (“MHz”).
1,000,000,000 Hz is a gigahertz (“GHz”).
174
frequencies are within the RF band of frequencies.95 Most of the observed “noise”
spikes are in the range of 2 to 50 kHz (2,000 to 50,000 Hz).96 The switching RF
“spikes” are variable, and they are being imposed on the 60 Hz house electricity
wave,97 creating significant unintended RF “noise.”
16. These frequencies are present all the time but are worse when less
electricity is being used (e.g., at night) and when the smart meter’s electronics need
more power, for example, when transmitting RF bursts to the utility. These RF
transmission bursts cause spikes over the electric wiring, and they are created
because the SMPS has to suddenly supply more DC power.
Digital Meters Use SMPS and Therefore Also Created Unintended RF
17. Digital meters also use SMPS. Therefore, even though they do not
contain an RF communications antenna, the AC/DC conversion process creates
significant and variable RF spikes over the electrical wiring, which is then radiated
into the house.
95 FCC defines RF as frequencies between 3 KHz – 300 GHz.
96 Finding of Fact 87 in McKnight v. PECO (once of the cases on hold below) states
that “PECO’s AMI meters do not produce 5 Hz, 3 kilohertz, or 5 megahertz fields.
(April 13, Tr. 75-76).” While I have some doubt this is actually so, this finding does
not rule out emissions in the other frequencies I list.
97 Electricity comes to the house at a frequency of 60 Hz.
175
Analog Meters Do Not Have SMPS and Do Not Create RF Spikes
18. In contrast, unlike wireless smart meters and digital meters, analog
meters do not contain an SMPS or other electronic components that create
unintended RF frequencies. No AC/DC conversion is necessary, and unlike smart
and digital meters, analog meters have a separate wired grounding rod that
eliminates much of the “noise” that may come from the energy feed.
19. The images below compare a smart meter like that used by PECO98
with an analog meter. The red waveform is the 60 Hz house electricity frequency.
The yellow waveform indicates the RF frequencies imposed over the 60 Hz. Image
1shows that an analog meter does not create RF spikes. Image 2 shows the smart
meter causing significant RF spikes “noise” over the 60 Hz frequency house electric
wiring system. 99
98 https://childrenshealthdefense.org/wp-content/uploads/pa-amicus-bathgate-pa-
smart-meters.pdf. Pages 17-18.
99 https://childrenshealthdefense.org/wp-content/uploads/pa-amicus-bathgate-pa-
smart-meters.pdf#page=14.
176
Image 1: Analog Meter – No RF Spikes

Image 2: Smart Meter – Intense RF spikes.

My Smart Meter Testing:
20. My test setup consisted of a meter socket enclosure suitable for
120/240 Volt, single-phase, three-wire connection. A smart meter, Landis & Gyr,
177
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Gridstream RF, Focus AXR-SD, Form 2S, CL200, 240 V, 3 W, 60 Hz, power
meter was used.100 The voltage waveform was captured with a Fluke 215C
Scopemeter. One input to the Scopemeter was connected to the incoming voltage,
120 Volts-to-Ground, unfiltered. The other input to the Scopemeter was connected
to the incoming voltage with the 60 Hz waveform filtered out. A radiofrequency
emissions meter was also used to indicate when an RF signal increase was
detected.
21. When the test equipment was connected to the incoming power, the
waveform of the incoming electrical power was observed. The 60 Hz signal was
recognized as the dominant frequency with some noise observed on the waveform.
The 60 Hz was filtered out to analyze the noise on the signal.
22. When the smart meter was not connected, the noise level was
approximately 45 milliVolts at its peak. When the smart meter was added to the
circuit, the noise on the 60 Hz sine wave was noticeably larger, approximately 85
milliVolts. This is nearly double the amount of noise than without the smart meter.
23. The dominant frequencies are in the range of 2 to 50 kHz. These are
the frequencies that the “smart meter” generates when it is transmitting.

100 PECO uses this meter, or one quite like it. R995a, 1046a.
178
Conclusion and Opinion
24. There is no doubt that smart and digital meters create pulsed RF
emissions and these emissions, from the smart meters’ antennas and the RF created
by the SMPS, both enter the house’s electric system. The result is that the entire
house is transformed into a radiating RF antenna.
25. Any meter with a switch mode power supply will create RF
frequencies in the Kilohertz range that enter the electrical wiring system of the
house. Smart meters and digital meters inject significant levels of RF onto the
home’s electrical distribution system.
26. This report is based on information learned to date. I reserve the right
to amend, clarify, or change my opinions based on more work or information
learned.
Respectfully Submitted:

Erik S. Anderson, P.E.

179

ENGINEER REPORT – Exhibit 1

180
ANDERSON ENGINEERING OF NEW PRAGUE, INC.
9007 S. Third Street Phoenix, Arizona 85042
Office: [phone] Mobile: [phone] Email: [e-mail]
ERIK S. ANDERSON Registered Professional Engineer REGISTRATION:
State of Minnesota 1991 21471
State of Illinois 1999 062052733 State of Arizona 2003 39627 State of Wisconsin 2008 39418-006 State of Indiana 2008 PE.10809314
State of Iowa 2008 18758
State of New Mexico 2008 19001 State of Texas 2009 102714 State of Louisiana 2009 PE.0034787 State of California 2010 105359
State of Kentucky 2012 28492
State of Michigan 2013 6201060247 State of Nevada 2013 022690
Licensed Class A Master
Electrician – State of

EDUCATION: B.S. in Electrical and Electronic Engineering North Dakota State University, Fargo, North Dakota, 1987.
Chemical Engineering Course Work
University of Minnesota, Minneapolis, Minnesota, 1981-
181
CONTINUING
Annual 8-Hr. HAZWOPER Refresher Course: 2009, 2010,
Minnesota Electrical Association – National Electrical Code
Instructor: Forensic Electrical Engineering Principles & Practices,
01/05 - Present

President & Forensic Electrical Engineer. Responsible for all
aspects of business operations including engineering services
to clients, analysis.
182
Our case load also includes construction defect cases
involving the evaluation of the workmanship of the electrical
subcontractor and personal injury cases involvi
Electrical Engin
failure analysis. Midwest Current Transform
Engineering of New Prague, Inc., New Prague, MN.
Designer, manufacturer, and quality
Research and Design Coordinator. Duties included work on
(Summers) Assistant Engineer. Designed software for and compiled data of E-fields generated by high voltage tassisted in investigations of various cases involving questions
AFFILIATIONS: Member National Society of Professional Engineers. Member Minnesota Society of Professional Engineers.
Member International Association of Arson Investigators.
Member National Fire Protection Association. Member National Association of Fire Investigators. Member American Society of Heating, Refrigerating and Air-
TESTIFYING WITNESS:
Corporation

183
BUILDING BIOLOGY INSTITUTE
REPORT
184
IN THE SUPREME COURT OF PENNSYLVANIA
MIDDLE DISTRICT
RE: No. 34 MAP 2021, Povacz, M, et al. v. PUC
Associated Case(s):
35 MAP 2021 Consolidated
36 MAP 2021 Consolidated
37 MAP 2021 Consolidated
38 MAP 2021 Consolidated
39 MAP 2021 Consolidated
40 MAP 2021 Consolidated
41 MAP 2021 Consolidated
42 MAP 2021 Consolidated
43 MAP 2021 Consolidated
44 MAP 2021 Consolidated
45 MAP 2021 Consolidated

THE BUILDING BIOLOGIST INSTITUTE REPORT

General Statement
1. My name is Lawrence James Gust. I am the President of the Board of
Directors of the Building Biology Institute (BBI).1 I have a degree in electrical
engineering and an MBA. I have been an environmental consultant for over 20
years and have trained hundreds of environmentally safer buildings consultants via
the BBI.
2. The Building Biology Institute (BBI) is a 501(c)(3) non-profit
corporation. BBI was founded in the US in 1993 and it follows the Principles of

1 https://buildingbiologyinstitute.org/about/our-mission/
185
the Institute fur Baubiologie und Ecologie in Germany.2 Our mission is to help
meet the ever-increasing public demand for proven methods that secure homes,
schools, and workplaces from toxic indoor air, tap-water pollutants, and hazards
posed by electromagnetic fields (“EMF”) and radiofrequency radiation (“RFR”)
exposure.
3. BBI offers three professional certifications: (1) Building Biology
Environmental Consultant (BBEC); (2) Electromagnetic Radiation Specialist
(EMRS); and (3) Building Biology New Build Consultant (BBNC). Each
certification requires the participants to complete online courses, participate in a
multi-day on-site seminar, undergo a mentored final project and pass various tests.
To be listed as a practicing professional on the BBI website,3 certified BBEC
professionals must obtain approved continuing education credits.
4. Our trained RF/EMF mitigation consultants measure the
electromagnetic fields and radiation at the site, provide a plan on how to mitigate
these emissions and work with other professionals such as electricians and IT
professionals to put in place the identified mitigating measures.

2 https://www.ibo.at/en/
3 https://buildingbiologyinstitute.org/find-an-expert/certified-
consultants/electromagnetic-radiation-specialists/.
186
5.Most of our clients are people who are sick or have family members
who have adverse reactions to RFR exposure. As with other environmental toxins,
and according to doctors, avoidance is the main and most effective treatment for
those who are affected. Our services help them mitigate exposures in their homes,
so they are part of the medical regimen prescribed by doctors. Many physicians
encourage their patients to contact building biologists to optimize their living
environment.4
6.We have a unique perspective and specific protocols driven by our
extensive science-based knowledge, methods as well as experience working with
those who suffer. Every day we see the widespread sickness caused by wireless
devices and infrastructure. We personally witness how devastating this sickness is.
Most important, we know our methods significantly improve the health and well-
being of those who must avoid RFR. Remediation efficacy is well documented and
undeniable.
7.Our knowledge and experience will provide the court valuable and
important information necessary to reach a just decision in this case.
Smart Meters
4https://www.womenscollegehospital.ca/assets/pdf/environmental/Preliminary%20
Clinical%20Guidelines%20%20for%20EHS.pdf#page=18.
187
8. We often confront sickness caused or exacerbated by smart meters.
Simply removing the meter often leads to immediate and consequential health
improvement. Unfortunately, we also routinely witness intolerable suffering by
those forced to have smart meters as a condition of service without any means to
opt-out.
9. People can turn off their cell phones, they can turn off the Wi-Fi in the
router and use hard-wired internet. They cannot turn off the smart meters and
therefore are forced to be exposed to the toxin that caused them to be sick 24/7, in
their home. It is a torture.
Demand increase correlates with exposure growth
10. There has been a significant increase in requests for our RFR
mitigation services over the last 20 years. Wireless services were first
commercialized for the mass market in the mid-1980s. Back then and for around
10 years RFR mitigation was a very small part of our work. But that began to
change in the early 2000s. Demand for our services has skyrocketed. RFR
mitigation is now the most frequently requested service in our portfolio and
constitutes about 75% of what we do. BBI consultants have a hard time fulfilling
the demand. This directly correlates with and is the clear result of with the
exponential growth in public exposure to wireless related pulsed RFR from
wireless devices and infrastructure. Pervasive and chronic exposure leads to
188
endemic sickness. We see it every day in our work, and it is devastating for those
who are afflicted.
11. This increase in demand is also reflected in the number of
professionals who are taking the certification course and become a certified
“building biologist.” Since we started to operate, 27 years ago, we have certified
approximately 308 building biologists. Thirty percent of them, approximately 100,
were certified in 2020/2021.
Collaborating With Treating Physicians
12. We collaborate with doctors whose patients suffer from electro-
sensitivity. The only effective treatment is avoidance and in many cases the house
is the cause or at least an aggravating factor for their patients’ illness. Doctors refer
their patients to us, as ensuring that the home environment of those affected is as
clean as possible from pulsed RF radiation is critical for any improvement.
Human Consequences
13. The human dimension of electro-sensitivity is tragic. People with the
condition call me and other building biologists in ever increasing numbers. In
many cases, people who used the technology “normally” and had no medical issues
suddenly become ill. They share with me the overwhelming and life-altering
changes confronting them when they or their children become sick. They literally
beg us to help them return to a normal life.
189
14.These people endure tremendous physical suffering. Frequent and
debilitating headaches. Inability to sleep. Heart arrhythmia. Pain in extremities.
Burning skin. Mental confusion, cognitive problems, and memory loss. Non-stop
ringing in the ears. Persistent nosebleeds are also common, especially with
children. For many the symptoms are disabling and prevent them from functioning.
They endure social isolation. They cannot work, go or be anywhere. Their lives are
becoming increasingly impossible. In addition, they have to deal with ignorant and
cruel denial of their condition because their sickness is an inconvenient problem to
those promoting wireless technology.
15.The problem is real and overwhelming. BBI’s certified practitioners
operate at ground zero. They alleviate the suffering of a rapidly growing number of
people across the United States. Building Biologists often care for clients who are
severely ill and desperately struggling simply to survive even in their own homes.
For these individuals and their families, the implementation of mitigative measures
recommended by BBI’s certified consultants offer the first and last resort. For
these clients and thousands like them, the services of Building Biologists are
lifesaving.
16.Many of our clients are unable to work because places of employment
are saturated with wireless devices. They are unable to drive to work because
roadways are flanked by cell towers irradiating passing vehicles with very high and
190
ever-growing RF levels. They are unable to live in urban and suburban areas
because houses are being irradiated by ever increasing numbers of cell phone
antennas, neighbors’ wireless devices and – as here – from utility smart meters.
17. However, when remediation reduces pulsed RFR radiation by
shielding the residence, symptoms usually abate or reduce, depending on the initial
power density and the overall ability of the shield.
RF Levels
18. The levels of pulsed RF radiation we measure (shown in power
density) are usually well below the FCC guidelines. However, power density is
still significantly millions and trillions of times above natural environmental
levels,5 and sometimes millions and more times higher than the levels that can
cause adverse health effects reported in peer-reviewed research.
19. The FCC guidelines are not biologically-based and not evidence-
based. The FCC guidelines do not address non-thermal effects or pulsation and
they average exposure over 30 minutes (which hides the true biological response to
exposure) and test for exposure from only one device. They do not protect from
chronic long-term exposure or from exposure to multiple devices, radiation
sources, frequencies, and modulations. They do not protect the public health, or at

5 https://www.thelancet.com/journals/lanplh/article/PIIS2542-5196(18)30221-
3/fulltext.
191
least not for a significant part of the population. Our clients are the evidence, and
the growing sickness is a clear proof this is so.
20. The FCC’s averaging does not account for pulsed digital signals
occurring in milliseconds. Therefore, they vastly underate the power density
(typically measured in milliwatts per square centimeter, or mW/cm2) that the
human body must deal with on account of unremitting exposure to pulsed,
modulated radiofrequency radiation. We see the peaks and pulses hidden by
averaging, and witness first-hand what it does to people. BBI practitioners measure
the aggregate RF exposure on the human body when in clients’ homes.
Shielding
21. Those affected by RF/EMF face a living hell. They cannot be or go
anywhere. Their home is their only refuge. Even this refuge is constantly under
threat, and many are required to shield their homes. Reducing RF levels enough to
be effective is a costly process. Unfortunately, the expense prevents many people
from effecting the best remediation plan or any plan at all.
22. Shielding is expensive because the shielding materials are metal
based, as metal blocks radiation. For example, shielding a parent’s queen size bed
with an RF protection tent ranges from $1,250 to $1,700 depending on the
shielding capability of the material. Shielding a child’s single bed will cost
between $1,000 to $1,400. Instead, it is possible to shield the bedroom itself by
192
painting the walls with RF protection paint and putting RF protection film on the
windows instead of tenting the bed. The cost for an average 12’ x 12’ bedroom is
$2,450. A family with two children would have to spend about $7,350.
23.Building Biologists focus on shielding sleeping areas because this is
where people are most vulnerable to RF radiation. But this alone does not
adequately protect people who are home all day.
24.Whole-house RF Radiation reduction requires painting the outside of
the house and the inside ceiling on the top floor with an RF protection paint. The
cost for 2,000 square feet is approximately $14,000. This cost is for two coats of
paint. But with growing RF levels, three coats are often needed, so the cost is
higher.
25.Metal reflects RF back into a shielded area. Therefore, whenever these
materials are applied, a careful analysis is required to ensure the materials do not
actually increase exposure. Shielding requires experts to do the job and this
increases total cost.
26.People sick from environmental exposure should not be forced to be
exposed in their home to the toxin that makes them severely sick. The considerable
cost of creating a livable environment is unfairly shifted to the injured, who have
no ability to recover from those who caused the injury.
193
Shielding & Smart Meters
27.Shielding materials attenuate the radiation, they do not entirely block
it. Reducing exposure enough to have a salutary effect is becoming increasingly
difficult because of the densification of wireless infrastructure including 5G, and
because home devices are becoming more powerful.
28.Smart Meters are without a doubt one of the most significant problem
sources. In 2013 I filed a letter with the FCC in response to the agency’s 2013
inquiry whether it should review its 1996 guidelines. I wrote to the FCC that the
most significant frequent initial sensitizing event we have seen over the last two
years has been the installation of smart meters. Now, 8 years later, this is still true.
Smart meters are the most significant sickness agent we must confront. 5G
antennas near homes is yet another major sickness agent, but they, at least, do not
typically also cause conduction through the homes’ over the cage of wiring that
encircles the entire living space– in the walls, ceiling and floor.
29.Smart meters’ antennas send intense RF pulses every few seconds and
these emissions affect the entire house. Proximity of the RF radiation-emitting
source directly impacts our ability to attenuate the radiation, as radiation drops
with distance. Smart meters’ location on or in close proximity to the house is why
they are the worst offenders for those who suffer from pulsed RFR.
194
30. The radiation from meters installed further away from the house still
creates RF inside the house. The RF frequencies from the antenna and from the
switch mode power supply are conducted through the house electric wiring. This
pulsed RF radiation enters the living spaces through the floors, walls, and ceilings
and via the power cords on all plugged-in electrical devices.
31. While one can take measures to reduce the radiation from smart
meters’ antennas, shielding from the RF emissions that go into the house electric
wiring system from the RF antenna and from the switch mode power supply
(SMPS) is complex, expensive, and not very effective.
32. There are filters that help reduce the RF “noise” created by the
meter’s switch mode power supply that conducts through the electric wiring.
However, some are very expensive. Others emit high magnetic fields that are also
problematic for those who are sick. Filters provide only partial solution as many
reduce higher frequencies while creating new, lower frequencies that are below the
typical measurement range of the meter.
33. Shielding is used to block radiation coming from the outside.
Shielding materials should be installed only when no pulsed RF-based wireless
devices are in the house.6 Otherwise, the shielding would be counterproductive and

6 Part of our remediation includes eliminating all other emission sources inside the
house, including things like SMPS used in laptop computers or other electronic
devices or wireless “Internet of Things” devices. Our clients can control such
195
even increase exposure because the inside-home emissions become “trapped”
within the house because of the shielding. For that reason, shielding the house from
outside sources can aggravate the problem caused by smart and digital meters.
34.A smart or digital meter on a house with resident adults and children
who adversely react to RF/EMF harms them both directly and indirectly. They
directly suffer from the meter effects, and they cannot shield emissions from the
outside like from cell towers, or neighbors’ smart meters and Wi-Fi networks.
Conclusion
35.People are being told that wireless technology is safe. That smart
meters are safe. They trust the government and the equipment manufacturers to
have their best interests and safety at heart. Nothing is further from the truth as the
recent case of the Children’s Health Defense against the FCC exposed. We see the
devastating sickness daily in our work. We hope this court will protect those who
need it the most.
36.The only reasonable accommodation for those who suffer from pulsed
RF radiation is an analog meter. They are the only meters that do not emit RFs and
do not aggravate the situation of those whose life is already a torturous nightmare.
Analog meters are inexpensive, last much, much longer than digital meters - they
things. But they cannot control what the smart or digital meter does nor can they
turn it off.
196
cost less than $100, and they have served us reliably for many decades. There
cannot be any justified reason not to accommodate the sick when the solution
exists.
cost less than $100, and they have served us reliably for many decades. There
cannot be any justified reason not to accommodate the sick when the solution
exists.
cost less than $100, and they have served us reliably for many decades. There
cannot be any justified reason not to accommodate the sick when the solution
exists.
197
lly Submitted:
a,,,,}(J,e,Y'Jce., . I~ k-
9, 7 .. 2(
Lawrence James Gust