Submission to the Essential Services Commission of Victoria
SSMA provided feedback to the Electricity Distribution Code Review. Our submission focused on the need for the Code to place greater focus on protecting Victorians from unintentional irradiation form transmission lines, distribution lines and electrical equipment. This is particularly relevant as EMF pollutants from the grid are also entering homes, and being broadcast from household wiring.
Stop Smart Meters Australia’s submission concentrated on the relationship between exposure to pulsed wireless smart meter emissions and poor sleep outcomes.
Stop Smart Meters Australia’s submission focused on the link between escalating levels of EMR and microbial multiplication in the environment and our bodies.
SSMA commented on Coliban Water’s Pricing Submission 2018, pointing out that its commitment to roll out smart water meters across its region did not take into account health costs. Imposition of Time of Use tariffs was also questioned.
ACMA invited comment on its Spectrum for broadband in the millimetre wave bands consultation. The ACMA will be using feedback from the consultation process to assist in early consideration of release of 5G spectrum. SSMA’s submission requested that a moratorium be placed on the release of 5G mmWave bands until such time as potential risks to humans and the environment have been assessed by scientists who are not funded by industry.
The Government invited feedback on proposals to amend legislation (the Telecommunications [Low-impact Facilities] Determination 1997, the Telecommunications Code of Practice 1997 and potentially, Schedule 3 to the Telecommunications Act 1997) in order to make it easier for carriers to install and maintain telecommunications infrastructure. If implemented, these changes will further reduce the ability of local councils and the public to object to the deployment of irradiating infrastructure. The amendments would also pave the way for the rollout of 5G. SSMA pointed out in our response that the classification of ‘low-impact’ has no bearing on potential harm to humans and the environment as a result of radiofrequency radiation from this infrastructure. We provided information which contradicted the consultation paper’s claim that ARPANSA exposure limits are set well below the level at which adverse health effects are known to occur.
Presentation to EMERG (ARPANSA)
Steve Weller, SSMA’s representative on ARPANSA’s Electromagnetic Energy Reference Group (EMERG), gave a presentation on bio-effects at EMERG’s bi-annual meeting held in May.
The Communications Alliance, a body which was formed to provide a unified voice for the Australian communications industry, sought comment on its Mobile Phone Base Station Deployment Industry Code (C564:2011). SSMA’s submission pointed out that local councils and the community are being denied the opportunity to meaningfully participate in mobile phone base station site selection and called for Australians to be given the right to influence the placement of base stations.
View 7 February public hearings transcript (pages 42-49 and pages 52-53)
Stop Smart Meters Australia’s submission focused on the Productivity Commission’s draft recommendation 9.1, which calls for the Australian Government to phase out Telstra’s obligation to provide landlines and payphones. We brought to the Commission’s attention the increased incidence of people with EHS in consequence of man-made electromagnetic fields, and the difficulties that this cohort would experience in rural areas reliant on satellite and Fixed Wireless NBN, if landlines are not available. In addition, we pointed out the possible long-term consequences of encouraging wireless uptake in rural areas. SSMA also participated in a public hearing and provided the Commissioner with further details regarding overseas initiatives and potential long-term health costs of abandoning the USO.
Submission to Standards Australia
Stop Smart Meters Australia commented on Standards Australia’s discussion paper on standards and the future of distributed electricity. In particular, SSMA recommended that all standards pertaining to technology capable of emitting EMF must also address the potential for harm to humans, animals and plants.
Correspondence between SSMA and DHHS
February 2015 – May 2016
View letters in 30 July 2016 post titled Victoria’s Department of Health continues to play pass-the-parcel with our health.
Victoria’s Department of Health & Human Services continued to deny legislative
responsibility for implementing policy to address the needs of people with electro-
hypersensitivity (EHS) or to agree to SSMA’s request to carry out a smart meter
post-rollout surveillance program.
Note: DHHS subsequently admitted legislative responsibility. See Health Department finally admits Health Act applies to health impacts of electromagnetic emissions
Letter to ARPANSA
22 February 2016
Stop Smart Meters Australia issued a community response to the Australian Radiation Protection and Nuclear Safety Agency, further to its statement following the airing of the ABC’s Catalyst episode entitled ‘Wi-Fried?’. SSMA members were very disappointed with ARPANSA’s statement and pointed out that it contained claims which are likely to mislead the public.
In response to the Australian Human Rights Commission’s National Inquiry into Employment Discrimination against Older Australians and Australians with Disability, SSMA recommended a national inquiry into human rights issues surrounding the rapid increase in the population’s exposure to man-made EMFs, strengthening of building codes to cater for the needs of EHS individuals and development of policies by the Department of Health to assist Australians with EHS to participate in the workforce.
Submission to the Energy Network Association (ENA)
Stop Smart Meters Australia (SSMA) commented on the ENA’s draft EMF Handbook. In particular, SSMA pointed out that the handbook should not conflate natural EMFs with manmade EMFs, needs to provide a balanced overview of the conclusions of scientific research, and that the scope of the handbook should include RF, legal liability issues and the means of mitigating EMFs inside buildings.
SSMA’s submission to the Department of Communications advocated for the regulatory functions of the ACMA to be separated from its role of raising revenue, to include within its remit responsibility for protecting the environment from emissions from telecommunication transmitters and creation of an Australia-wide database listing smart meter access point locations.
SSMA provided a submission to Urbis, the organisation commissioned to undertake the 2015 review of the Disability Standards for Education. The Minister for Education and Training, in consultation with the Attorney-General, is required to conduct a review of the effectiveness of the Standards every five years. SSMA’s submission, which focused on the needs of EHS students, was accepted, despite its late arrival.
Stop Smart Meters Australia commented on the effectiveness of Australia’s Disability (Access to Premises – Buildings) Standards 2010 (terms of reference). SSMA asked for the needs of EHS individuals to be catered for in the standards.
Stop Smart Meters Australia provided input to the 2015 review of Victoria’s Charter of Human Rights and Responsibilities Act 2006. Comment was sought on the public’s experience with the Charter, along with suggestions for improving its effectiveness (terms of reference).
Presentation to EMERG (ARPANSA)
Steve Weller, SSMA vice-president, presented on the topic of Electromagnetic Hypersensitivity (EHS) at the bi-annual Electromagnetic Energy Reference Group (EMERG) committee meeting. EMERG was established by the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) to enable input from the community and other stakeholders on issues relating to electromagnetic radiation and health.
Stop Smart Meters Australia commented on the AEMC’s consultation paper (AEMC’s announcement of consultation paper) outlining proposed changes to the National Electricity Rules (NER). Specifically, the COAG Energy Council and the Total Environment Centre (TEC) have requested changes to the current demand management incentive scheme available to distribution businesses, in order to more strongly encourage electricity distributors to favour demand management options over investment in network assets to cope with peak demand.
Submission to the Australian Law Reform Commission
Stop Smart Meters Australia provided comment in response to the ALRC’s Issues Paper on Traditional Rights and Freedoms—Encroachments by Commonwealth Laws (ALRC’s request for submissions). The ALRC has been given the responsibility to inquire and report on Commonwealth laws that encroach on traditional rights, freedoms and privileges, and to examine whether such encroachment is justified. SSMA’s submission centred on adverse flow-on effects as a result of legislation made under the Radiocommunications Act 1992 s 162 (1) (b).
Submission to the Department of State Growth, Tasmania
Stop Smart Meters Australia commented on the Tasmanian Government’s draft paper ‘Restoring Tasmania’s Energy Advantage’.
SSMA commented on the Federal inquiry into the performance and management of electricity network companies.
Submission to the Australian Energy Regulator (AER)
Stop Smart Meters Australia commented on the proposals received by the AER from the five Victorian electricity distributors for charges to apply to smart meters in 2015.
Letter to Federal Ministers
Letter from Stop Smart Meters Australia, which was provided to Federal Ministers at the National General Assembly, Canberra, asking for the ACMA’s regulatory functions to be hived off to a separate body, the application of the Precautionary Principle in the rollout of advanced metering infrastructure (AMI), clear labelling of AMI radiofrequency sources, and the establishment of radio-quiet zones for EHS (electrically hypersensitive) persons.
Stop Smart Meters Australia commented on the ACMA’s proposal to remake the Radiocommunications (Electromagnetic Radiation – Human Exposure) Standard 2003 and the Radiocommunications (Compliance Labelling –Electromagnetic Radiation) Notice 2003 legislative instruments without significant changes.
Stop Smart Meters Australia’s submission addressed the findings of the Victorian Auditor-General’s 2009 report Towards a ‘Smart Grid’ – the roll-out of the Advanced Metering Infrastructure.
Stop Smart Meters Australia commented on E3’s CONSULTATION REGULATION IMPACT STATEMENT: Mandating ‘Smart Appliance’ Interfaces for Air Conditioners, Water Heaters and other Appliances. SSMA did not agree with the recommendation to equip all air conditioners and other nominated appliances with an AS/NZS 4755 smart appliance to enable electricity utilities to remotely cycle off power to appliances owned by participating customers.
Stop Smart Meters Australia commented on ESV’s Safety of Advanced Metering Infrastructure (AMI) in Victoria: Draft report.
Letter to Victorian Liberal Delegates
Letter from Stop Smart Meters Australia, calling for an immediate halt to the mandated rollout of smart meters in Victoria, which was distributed at the State Liberal Party conference.