Electric Vehicle (EV) Critique

 

 

 

Criticism jointly submitted to the Massachusetts Department of Public Utilities dockets 21-90, 21-91, and 21-92 on utility EV proposals on 14 September 2021 — available at MA DPU, but link may change after corrected copy is provided. Ken Gartner also provided a separate letter including more technical criticism.

 

Dear Secretary Marini:

All of the proposals from the above-captioned utility plans sound wonderful if one believes electric vehicles (EV) are the route to preventing climate disaster. However, sound environmental and public health reasons exist to stall these proposals for modification or elimination, in addition for privacy and property protection.

PROPOSED ELECTRIC VEHICLE (EV) INFRASTRUCTURE

The following, with some slight variation, describes utility proposals, which are based upon published directives for electric vehicle infrastructure in D.P.U. 20-69-A, and the rate structure for demand charges regulated by Section 29 of Chapter 383 of the Acts of 2020 (the ‘Transportation Act”):

1. Financial support to provide:

    • In public sites and workplaces, Electric Vehicle Supply Equipment (EVSE) installations, for Level 2 (L2) chargers;
    • Direct Current Fast Charging (DCFC) in environmental justice communities or in public sites and workplaces;
    • In properties with 1-4 units and multi-unit dwellings, EVSE and at-home charging enabling;]
    • EVSE installations in light duty fleet, including school buses;

2. Pilots to support electric fleet conversion in ‘environmental justice’ communities;
3. Workforce development and electrician training;
4. Demand charge alternative rate structure with a sliding scale, in accordance with the Transportation Act.

RADIOFREQUENCY GUIDELINES LACK AUTHORITY

Of great import, in Environmental Health Trust v. Federal Communications Commission, No. 20-1025 (D.C, Cir. 2021) the court held that the FCC failed to provide a reasoned explanation for deciding its radiofrequency guidelines are safe. This decision, unusual in chastising the FCC’s inquiry decision, upends any claim of safety and reliance upon FCC guidelines, and now the FCC must again review and reconsider its guidelines.

Given this court decision, the Commonwealth, department, and utilities should stall investments into EV and EV infrastructure, in addition to the smart grid, in order to limit radiofrequencies.

EVALUATE & LIMIT RADIOFREQUENCY EXPOSURES

Secondly, the scientific evidence that these exposures are harmful should be seriously evaluated, and appropriate action taken to limit exposures from existing infrastructure.

Relevant health studies can be found on the Aachen University EMF Portal or at PubMed, and in addition experts independent of industry can assist with review and considerations such as safer options.[1 2 3 4 5 6 7 8 9 10] The International EMF Scientist Appeal is a good starting point for identifying and contacting credible scientists and public health doctors independent of industry, while the Institute of Building Biology is another for identifying engineers and building biology consultants who have studied remediation.

While utilities and the department can adopt the ALARA principle, ‘As Low As Reasonably Achievable’, radiofrequency exposures from EV infrastructure and EVs, including electric fleets, require time and study for remediation and appropriate investment.[11 12] Hence, EV infrastructure should be delayed.

If utilities and the department proceed with electric cars and corresponding infrastructure, then powering these cars must be planned carefully. Utilities and the department can take steps to limit transients, harmonics, etc., on the power lines from EV, in addition to heavy loads that create strong fields, as well as wireless signals. Technical problems, such as ground current, ground faults, and fire hazards, which also need to be addressed, are discussed by Ken Gartner in his testimony to these dockets – he also suggests a permitting process for all EV chargers.

As a matter of transparency and accountability, utilities should provide public information on existing radiofrequency exposures, including power quality, as well as utility remediation efforts and potential hazards.

HEALTH IMPACTS OF EV INFRASTRUCTURE

Poor power quality results when electrical lines carry extra frequencies ranging from less than 5 kHz to more than 500 kHz. Poor power quality may cause calcium to be deposited in the heart, thereby damaging the heart, or may cause other health issues.[17 18 19] EVs and EV infrastructure will compromise the power quality of electrical lines in areas serviced, including in targeted environmental justice communities, workplaces, and multi-unit dwellings.

A recent study discusses how Direct Current Fast Chargers will cause enormous power quality problems, but recommends a solution.[20] How much of a solution is this and is this tenable?

Another recent study found that magnetic fields are often dangerously high near Direct Current Fast Chargers.[21] If installed in environmental justice communities as planned, how is this an environmental justice? If these are installed near parks, where children rest and play, or adjacent to a bedroom how will the hazards be eliminated?

Future EV infrastructure may even include wireless charging, which will simultaneously lead to strong magnetic field exposures capable of disrupting medical devices.[22 23] EVs already have
wireless emissions embedded, requiring calculations of multiple sources of exposure in concert with utility equipment.[24]

Dr. Ron Kostoff, with a Ph.D. in Aerospace and Mechanical Engineering from Princeton University and who has worked for Bell Laboratories, Mitre Corporation, and the Department of Energy, has noted that he cannot find measurement devices to measure the ~24 GHz and ~77 GHz frequencies emitted as part of ‘safety’ sensors in modern vehicles, but he can find indications levels are directed at passengers and likely exceed thermal levels.[25]

Researchers at the University of Mainz measured brain activity of a driver who step-by-step turned on the car, the air conditioning, the cellphone connection, and the WLAN with alarming disruption evidenced.[26] Research repositories are ripe with evidence that these exposures are harmful, so why build infrastructure rife with these exposures?

Assumptions need to be challenged. For example, as part of ‘Equity pilots’ in environmental justice communities, Eversource proposes a car-sharing program that may cost more or less than $2,000,000 and also proposes to establish electric fleets such as for buses and community transport that may cost more or less that $3,000,000. [27] Establishing these programs in environmental justice communities ironically causes harm, misleading consumers, while simultaneously charging for the opportunity.

Many questions exist, and the department and utilities need to find answers and share these with the public. For example, what are the measurements of power quality, power frequency fields, and radio-frequencies from Electric Vehicle Supply Equipment and other types of installations? Are there wireless components within the infrastructure and, if so, can these be proven safe or eliminated? Are there hazard zones?[28] Can hazard zones be fenced? Is wildlife at risk? What is the cost of remediation? Are there differences between public, corporate, and occupational exposures?

ENVIRONMENTAL IMPACTS OF EV INFRASTRUCTURE

Wireless, electromagnetic noise, and strong fields from electricity are known to disturb flora and fauna, such as by sickening trees, disorienting birds, and interfering with hunting and nesting.[29 30 31 32] Fostering wireless also threatens climate by contributing to global warming, because radiofrequencies contribute to heat.[33] Dielectric heating from wireless also harms insects like bees.[34 35]

The entire purpose of moving towards EVs is protecting our environment by reducing carbon emissions, but needs to be assured rather than assumed. EVs can have greater carbon emissions than gas-powered vehicles when relying fossil fuels.[36] The biomass industry is also agitating hard to be allowed into the federal renewable energy standard, yet consumes mature trees at a pace faster than regeneration, contributing to carbon emissions through hauling, fuel burning, and loss of carbon sinks.[37 38]

Modern EV infrastructure resource demands have not been factored into energy-use calculations.[39 40] For Level 2 chargers along streets alone, as expressed by Unitil, requirements include replacement of street pole, installation of underground electricity service, 3 pole-mounted transformers, a weather resistant cabinet, excavation, concrete footing, grading, utility meters, distribution panels, conduits, and breakers.[41 42] Loss of energy and equipment damage is a known effect of poor power quality, which results from EV infrastructure – this also needs to be factored into energy calculations. [43 44 45 46 47] Katie Singer has also referenced reports that EVs will require more energy consumption than gas-powered automobiles, while adding to E-waste and contaminating water – these reports deserve investigation.[48]

A cradle-to-grave environmental evaluation of electric vehicles and infrastructure is needed that is fully funded, independent of industry influence, and which evaluates energy footprint, resource consumption, service life, end-of-life removal costs, and environmental toxicity in addition to alternatives.

Independent evaluation is needed to compare electric cars to other investments, such as alternative fuels like hydrogen, different transportation systems, energy saving strategies, infrastructure efficiency, life-style adjustments, and urban planning impacts.[49 50 51 52] For example, quarantine led to significant carbon emission reductions in China. [53] Climate quarantines can cause disparate economic harm, but investments in alternative economies and urban planning can respectfully reduce automobile reliance.

PROPERTY DAMAGE FROM EV INFRASTRUCTURE

EV infrastructure presents significant potential for property loss, and this needs to be factored into budget projections and comparisons to alternative solutions.

Poor power quality can damage property, causing equipment deterioration, shutdowns, and misoperation at home and work.[54 55 56 57] A 2008 in-depth European Power Quality study found industrial loss to be 4% of turnover rate, even exempting data centers, and in excess of 135 billion Euro within Europe.[58] A 2001 study found a 2-second power quality interuption cost industry $37.03/kW.[59]

Cyberattack on EV chargers could damage home or community power distribution, service, and hardware; hacks may disable or command a single vehicle or a fleet; access home WiFi or a mobile App, and steal data for identify theft. [60 61 62 63]

Who bears liability for dangerous and poor investments? Filings in the above-captioned and other D.P.U. dockets by numerous parties are warnings based upon peer-reviewed science, likelihood of lawsuit, and potential for a court ruling that makes smart grid investments obsolete.[64 65 66 67 68] Liability may exist for infringements on constitutional privacy, property rights, and health.

RECONSIDER EV INVESTMENTS

In light of the foregoing, EV costs and investments need to be reconsidered. Total EV infrastructure spending forecast is estimated as $469.7 million in total from National Grid and Eversource, while Unitil lists $1.01 million.[69] These investments should be set aside and remediated or reconsidered. Why not instead invest in a car-free future, like Barcelona?

Utilities have a conflict of interest which may explain their drive even when new technologies fail to live up to marketing expectations. Investor-owned utilities can earn a profit, a Return On Equity invested (ROE) into distribution infrastructure:

Utilities profit primarily by buying new equipment (“smart” meters, power lines, transformers), charging ratepayers interest on this investment and paying less taxes as the equipment depreciates over time. The higher the investment risk, the higher the rate of return. The rate of return decreases each year. Once the rate of return reaches zero, the utility operates and maintains the equipment with no profit.[70]

Eversource reported an increase of 34% in profits for 2021 – this is an enormous profit.[71]

The utility profit model needs to be redesigned to encourage saving money, energy, health, nature, and existing investments.

In sum, here are the final recommendations for the department and utilities:

• Stall EV infrastructure plans;
• Adopt the ALARA principle;
• Establish policies to regularly monitor and share with the public electromagnetic measurements from the grid, including before and after corrective measures.
• Based upon a full accounting, examine whether EV infrastructure and EVs saves or costs resources and energy;
• Examine how EV infrastructure can be modified to respect privacy and protect reliability and security;
• Identify if liability remains, for whom liability exists;
• If EV infrastructure is a net environmental positive and health can be protected, prepare an adjusted budget and timeline to reflect new expenditures to fix problems;
• If remediation is not possible or problematic, lobby the legislature to halt EVs and attendant infrastructure.

Signed 14 September 2021 by:

Kirstin Beatty
Director, Last Tree Laws
149 Central Pk Dr
Holyoke, MA 01040

Patricia Burke
Stop Smart Meters MA
Halt MA Smart Meters
Scientific Alliance for Education
8 Eden Street
Mills, MA

Leslie Saffer
Worcester Info Team for Health (WITH)
392 Mill Street
Worcester, MA 01602

Laura Josephs
7 Conway Dr. #2
Greenfield MA 01301

Virginia Bradley Hines, PA, LMHC
Director, The EMR Network
Member, Concord Safe Technology [MA]

Liberty Goodwin, Director
Toxics Information Project (TIP)
P.O. Box 40572, Providence, RI 02940

Alexia McKnight, DVM, DACVR
258 Heyburn Rd.
Chadds Ford, PA 19317

Nikki Florio
Founder/Director of Bee Heroic
7823 W 38th Ave.
Wheat Ridge Colorado 80033

Eugene J. Bazan, Ph.D.
Secretary, PA Smart Meter Work Group
PO Box 24
Lemont, PA 16851
Lisa Lovelady
Stop 5GJax
4249 Ortega Place,
Jacksonville, Florida 32210

Cynthia Franklin, Director
Consumers for Safe Cell Phones
829 Briar Rd.
Bellingham, WA 98225

Endnotes:

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https://www.pouted.com/cyber-security-issues-of-internet-with-electric-vehicles/
62 Barney Carlson & Ken Rhode (2018 Sept 12) Cybersecurity of DC Fast Charging: Potential Impacts to the Electric
Grid. Idaho National Laboratory. INL/MIS-18-5128. Available 7 September 2021 at
https://avt.inl.gov/sites/default/files/pdf/presentations/INLCyberSecurityDCFC.pdf
63 Kim M, Park K, Yu S, Lee J, Park Y, Lee SW, Chung B. A Secure Charging System for Electric Vehicles Based on
Blockchain. Sensors (Basel). 2019 Jul 9;19(13):3028. doi: 10.3390/s19133028. PMID: 31324058; PMCID:
PMC6651179.
64 Ed Friedman v. Central Main Power Company. ORDER ON DEFENDANT’S MOTION TO DISMISS. No. 2:20-cv-
00237-JDL (1 st Cir. 2021) Available at https://ehtrust.org/wp-content/uploads/R.-Doc.-26-Friedman-ADA-Order-
Denying-CMP-MTD-3-31-21.pdf
65 Emily Cohen (2020 Nov 11) Court ruling throws Pennsylvania smart-meter plan into turmoil. The Philadelphia Inquirer.
Available 7 September 2021 at https://www.inquirer.com/business/peco-puc-pennsylvania-commonwealth-court-smart-
meter-decision-20201111.html
66 Consolidated brain cancer from cellphone cases currently winding through courts including Michael Patrick Murray, et
al., v. Motorola, Inc., et al.,” Case No. 2001 CA 008479 B in the Superior Court for the District of Columbia
67 See dockets 13-83, 20-69, 16-28, 17-53, 21-80, 21-81,18-28, 21-82, 21-90, 12-76 ALL critical submissions and
attachments including but not limited to that of Dr. Lisa Nagy, joint comments, Ken Gartner, Einar Olsen, Helen
Walker, Kirstin Beatty, MACI , Dr. William Maykel and Patricia Burke , Dr. Beatrice Golomb, Reply comments by
Patricia Burke, Kirstin Beatty, Kirstin Beatty, Jean Lemiux, Dr. William Bruno, Sandra Chianfoni and Laura Catullo,
Exhibit 3 by Kirstin Beatty, Thea Fornier Wireless Technology Health Effects, Dr. Robert Gilmore Pontius Jr, PhD,
EMR Policy Institute, Dr. William Rea, Dr. Carpenter, EMR Policy Institute, and many more in all the dockets far too
numerous to list here.
68 Ken Gartner observes, in his 21-90 to 92 testimony that the utilities offer to sell EV charging installations to
municipalities and that municipalities not only are poorly suited to manage such installations but will will be left liable.
What also is the cost of removing and recycling such installations? Reference: Massachusetts Electric Company and
Nantucket Electric Company each d/b/a National Grid D.P.U. 21-91 Exhibit NG-EVPP-1 (July 14, 2021) pp. 50-51
69 See Notice of Public Hearing filed in each respective docket for the utilities.
70 Singer, Katie. (3 Feb 2020) Basic needs, electrified: What we expect from electricity. Wall St. International Magazine.
https://wsimag.com/economy-and-politics/64758-what-we-expect-from-electricity
71 Crowley, B (21 Feb 2021) Strong Revenues in Connecticut Boost $1.2 Billion Profit for Eversource, CT Examiner.

Strong Revenues in Connecticut Boost $1.2 Billion Profit for Eversource

What’s with Agenda 21? UPDATED

 

What’s with Agenda 21?

by Kirstin Beatty – Updated 27 August 2021

 

I was curious what is with Agenda 21, tossed about as an evil by some, and examined complaints.

Honestly, my expectations were low. In the same way that governments state that continuing emissions at the current rate will lead to devastation yet continue enabling the same emissions, I expect similar, if less so, dissonant action from the United Nations.

First of all Agenda 21, now Agenda 30, is not mandatory or enforceable. Agenda 30 includes many laudable goals, such as recommendations to protect the rights of women and support environmental health for all.

Continuing with the positive, Agenda 30 seems to make some attempt to prevent big business from winning all contracts and owning everyone and everything. Small farmers, which have been decimated by the false promise of a green revolution and industrial agriculture, are to be protected from big business. Of course, protection may not exist in practice.

Secondly, the United Nations is an organization intended to share the thoughts of nations, or governments, rather than businesses. A one nation, one vote policy was intended to give even small, poor countries a say.

Isn’t discussion among nations helpful to preventing war? So, check, another positive.

Yet, in 2019, the United Nations made an accord with the World Economic Forum (WEF) to circumvent votes from each nation in favor of including business stakeholders in formulating decisions, as discussed in an article by Harris Gleckman on OpenDemocracy.net.

Ivan Wecke, in a recent article also posted at OpenDemocracy.net, discusses how the WEF chairman Klaus Schwab has promoted ‘stakeholder’ capitalism, intended to give corporations more power by setting aside democratic precepts of government so that corporations make decisions.

As with treaties and trade agreements, transnational corporations were welcomed to help craft the Agenda 30 vision, and Agenda 30 states that nations and ‘stakeholders’ (i.e. businesses) are to take apart in achieving the goals.

In other words, transnational businesses will have access to the U.N. plans most lack, and the time and wealth to ‘fix’ decisions with details against cheap solutions in favor of saleable investments. While U.N. plans are unenforceable, the plans are meant to guide countries and are influential.

To welcome transnational corporations into these discussions undermines the one nation vote policy and is a fundamental problem existing not only within the United Nations, but within U.S. local, state, and federal representative government, where businesses are often invited as ‘stakeholders’ into crafting laws and policies.

Even without being invited to help craft plans, transnational corporations can monopolize business opportunities and undermine competition. A more recent problem is that transnational corporations can frame the conversation and public attitudes towards these plans with technological propaganda and wealth. Advance notice of United Nation plans helps transnational companies revise, undermine, and outright oppose ideas shared by nation representatives.

With illusions created by wealth, transnational companies can sidestep real solutions and cause indirect harm, such was seen in the opioid crisis.

I haven’t read the entire document, but Agenda 30 emphasizes innovation, such as modern energy investments. Yet better, cheaper options may exist with older technology or with none at all. Yet, businesses are likely to argue otherwise due to conflicts of interest.

I’ve criticized the smart grid as costly and harmful for several years, but my criticisms have fallen on deaf ears in both business and government.

There is a positive statement advancing the concept of medicine for all, or of affordable medicine, which remains a dream in many countries, but nowhere does Agenda 30 address accountability for pharmaceutical companies regarding honest marketing and safer pharmaceuticals.

Covid-19 is a perfect example of how admirable goals can be circumvented. Vitamin C, D, antivirals, and any cheap treatment are not part of the conventional standard of care or of much consideration. Vaccines for all are being offered only at hefty prices and, with emergency authorization liability protections for indemnification through the U.S. PREP Act. Abroad, companies have refused to provide vaccines unless profits and indemnity are assured. In the USA, no payouts for any related adverse reactions have been made at all, despite 1,693 claims as of 2 August 2021. Any risk taken is a risk borne, apparently, only by the private consumer.

However, I can’t blame the United Nations alone, or transnational companies, for failing to consider pharmaceutical accountability. The United States has done little to halt conflicts of interests of government officers or to insure pharmaceutical accountability. The answer is to first set up laws in our own country to at least prevent conflicts of interests, such as the ballot measure proposed at Last Tree Laws.

As far as private property dispersal there is a vague statement that all should have equal access to ownership of property. Agenda 30 uses the words “access” to ownership, which suggests that the meaning is about preventing discrimination in ownership, such as the historic denial of home ownership to African Americans or in some countries to women and ethnic minorities.

Equal rights to economic resources is also discussed, which may involve rights to water as countries struggle over drought or rights to agricultural land for farmers. While a nice idea, this goal is likely to go ignored, especially since the United Nations cannot enforce any of its recommendations. Israel and Palestine battle over land in a way that shows just how useful recommendations for sharing are heard.

The arguments against Agenda 30 based on giving away private property are specious. If ‘property’ is ever shared freely by the wealthy, then it will be a cover for transferring liability or creating ‘sharecroppers’ of some kind.

As far as sharing wealth otherwise, Agenda 30 advocates for social protection measures and these, if business interests reign, may not necessarily equal high quality work, education, or housing. The idea is noble, but is for ‘coverage’ which, like insurance coverage, may come with conditions.

Presently, businesses are mandating medical treatment for Covid-19 — this sets a precedent to allow businesses to mandate any medical care for ‘societal good’ even if the concept of societal good can be manipulated and abused. At one time women were thrust tossed into mental hospitals on questionable psychological assessments, in order to limit their opinions or to acquire their property.

I also see a statement that private property cannot be an excuse to harm others through environmental devastation, with which I’m sure we can all agree. Do you want your neighbor or any business to be excused on the basis of personal property to place, on their property, a hazardous chemical dump next to your home?

In sum, the criticism of Agenda 30 across social media is largely about redistribution of private property, which is off base.

Is the criticism that Agenda 30 will mean loss of private property fabricated by corporate interests to divert attention from the positive goals of Agenda 30, including limits on corporate power, or to divert attention from the detrimental influence of business interests? The American Policy Center, at the forefront of Agenda 21 and UN criticism, has long campaigned against corporate regulation, including pharmaceuticals, and environmentalism under the guise of private property rights.

Criticism of Agenda 30 is also part of a campaign against the United Nations. Check the news, and you’ll see that there is a campaign against the United Nations as well – why, I’ve no idea. I may be against transnational companies participating, but not against the concept of the United Nations.

I see the criticism of Agenda 30 is often laced with the words communism and socialism. This seems like a trick to get people to automatically react badly to the words communism and socialism, when people should be able to discuss economic ideas calmly.

Socialism has been successful in cooperatively-owned businesses. In socialism, the means of producing or distributing goods is owned collectively, such as work cooperatives like Real Pickles. Socialism can also mean when the government owns the means of producing and distributing goods as exemplified in part by Medicare and Social Security. The U.S. military has been held up as a partly socialist system.

Socialism does not appear to be discussed in Agenda 30, and cooperatives are mentioned only as a business entity like any other — not with any preference.

There isn’t a country that is fully socialist, but several have adopted some socialist programs or policies. Denmark and Costa Rica seem to have done well with high taxes and universal health care as the National Geographic ran an article some years ago on how Denmark and Costa Rica have among the happiest people in the world.

There is not mention in Agenda 30 of providing universal health care, although universal coverage appears mentioned as part of ‘social protection’ — coverage comes with many more conditions than anything universally applied. Restructuring taxation is not mentioned either, except to restructure energy subsidies away from fossil fuels.

In contrast to socialism, communism has failed in many countries. Communism occurs when the community provides funds to the government for equal redistribution, but in practice governments have pocketed the money. Some have observed that communism could work on a small scale, such as within a tribal community.

The ideal of communism is nice, and deserves less hate.

Communism is often used as an insult because of its association with authoritarian governments but also, probably, since communism frightens the wealthy. At one time just being accused of being a communist destroyed careers of people who were not even communist as part of the ‘Red Scare’ propaganda. To weaponize the word communist or any other academic idea is dangerous as it supports aggression, censorship and undermines free discussion.

Associating Agenda 21 or 30 with communism is pushing it. The United Nations, full of capitalistic and some wealthy nations, is not going to become communist or, if so, not easily.

The use of communism and socialism as marketing campaign insult to Agenda 30 may be a marketing trick to create division and shut down discourse. Agenda 30 doesn’t, so far as I can see, have anything at all to do with socialism or communism. The criticism, if it is even a criticism, is way off base. I would say that is a marketing trick. If only criticisms exist of Agenda 30 as communism or socialism, which does not exist in the proposal so far as I can see, then critics must be dismissed and Agenda 30 must be a good thing. I would say the public is being misused to attack Agenda 30 on the wrong and imaginary basis, rather than on any real basis, and I wonder if leading critics are paid for by some party intent on sowing division and prejudices in the United States.

Or, I wonder if the criticism is simply to divert attention from more important avenues for change.