News Our Feedback to EC 19 August 2022

Have your say - SmartMeters

You can also get involved in forming EU laws. The European Commission would like to hear your views on laws and policies currently in development. They offer a platform "Have your say" with the list of all new EU initiatives open for public consultation. You need to register to write your feedback.

There are always 5 stages of each EU initiative, each stage is open for public consultation for a specific time frame:

  1. In preparation

  2. Call for evidence

  3. Public consultation

  4. Draft act

  5. Commission adoption

Access to electricity metering and consumption data – requirements

About this initiative: The Electricity Directive requires the Commission to adopt interoperability requirements and non-discriminatory and transparent procedures for access to data on metering, consumption as well as data required for customer switching, demand response and other services.

Feedback period: for stage 4 it is 29 July 2022 - 05 September 2022


Feedback from Europeans for Safe Connections

We "Europeans for Safe Connections" do not see the benefits for the EU citizens only for the big businesses. Radiation protection have been completely ignored in this draft. The Department of Environmental Medicine of the Austrian Medical Association (ÖÄK) warned against the widespread introduction of smart meters (SM) several years ago. SM lead to a significant increase in electrosmog exposure and thus to health effects. The German Federal Office for Radiation Protection warned already in 2016: "According to the principle of radiation protection to minimize or completely avoid exposure, SM that transmit their data by cable should be preferred."

We suggest the following changes:

Art. 2, point 3 defines: ‘validated historical metering and consumption data’ - data collected from a meter, a conventional or a SM. SMs were introduced as part of the Energy Efficiency Directive, to reduce energy waste. SMs have the capability to transfer data using the electrical grid system. There is no need to waste additional energy for wireless functionality. In short, the addition of a wireless functionality to SMs is unnecessary, costly and is a breach of the Energy Efficiency Directive.
See proposal 12 of our ECI

Art. 2, point 5 defines: ‘near real-time metering and consumption data’ - data provided continuously by a SM in a short time period, usually down to SECONDS. This is unacceptable for us. This rate does not help to save energy, only feeds big data. Once per hour/per day is enough and definitely not during night, when the human body regenerates through sleep. SMs shall not be placed near sleeping and resting areas and in areas near the residence of children, pregnant women, sick, sensitive individuals, and healthy individuals who do not wish to be exposed to RF EMF. We request that eligible party be obliged to provide an alternative that does not use wireless transmission. Customers must have the right to choose wired connection of meters instead of wireless. Otherwise there is discrimination against the health of vulnerable groups. Each person has the right to mental and physical integrity as stated in the Art. 3 of CFR. This includes also avoiding any disturbance and interference with their biological, chemical, electrical and sensory processes and systems by RF EMF.
See proposal 9 of our ECI

Art. 2, point 7 defines: ‘metered data administrator’ - a party responsible for storing this big data; Art. 2, point 11 defines: ‘metering point administrator’ - a party responsible for ... characteristics of final customers linked to the metering point. We require that these administrators are forbidden to be from a private sector. They must be some state departments.

Art. 2, point 8 defines: ‘permission’ - the authorisation given by a final customer to an eligible party... We require to explicitly write: "VOLUNTARY authorisation whereas not giving an authorisation may not mean stop providing services."

Art. 2, add point 18: ‘customer consent’ means an informed consent of a final customer to the meter operator meaning that he is aware of the RF EMF exposure and agrees to it. All SMs must be labeled visibly - CAUTION: ELECTROMAGNETIC RADIATION, WARNING: POSSIBLY CARCINOGENIC. Consider separation of outdoor and indoor supply of mobile / wireless radiation. Basic Law for the Federal Republic of Germany, Article 13, considers the home inviolable. This request is in line with the Article 114 TFEU and with WHO labeling - electromagnetic radiation is in group 2B (possibly carcinogenic to humans) and is expected to change into just ”cancer causing” (it is planned by IARC to review the classification in 2022-24)

Art. 5, add point 1e: Encrypt the transmitted data to ensure no unwanted access.

Art. 5, 1a mentions "non-discriminatory way" but point 1c mentions only "an online interface". This is discriminatory for people who do not have/do not want internet access.

Annex, row 17, information about SM. We require more information, including

- how often it emits radio signal
- the radio frequency
- the exposure level in µW/m2 for 3 distances: 1cm, 10cm & 100cm far from the source

Petra Bertova
on behalf of the Europeans for Safe Connections

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