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. 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. 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.
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.
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. 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.  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? 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. 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. 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.
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.  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. A 2001 study found a 2-second power quality interuption cost industry $37.03/kW.
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. 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.
Eversource reported an increase of 34% in profits for 2021 – this is an enormous profit.
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:
Director, Last Tree Laws
149 Central Pk Dr
Holyoke, MA 01040
Stop Smart Meters MA
Halt MA Smart Meters
Scientific Alliance for Education
8 Eden Street
Worcester Info Team for Health (WITH)
392 Mill Street
Worcester, MA 01602
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
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
4249 Ortega Place,
Jacksonville, Florida 32210
Cynthia Franklin, Director
Consumers for Safe Cell Phones
829 Briar Rd.
Bellingham, WA 98225
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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.
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