Standards Australia is seeking public feedback on a discussion paper it has released that considers smart meters and other technologies related to the generation and distribution of electricity.
The discussion paper is called Standards and the Future of Distributed Electricity and you can read it here.
You can make send your comments to Ms Jessica Curtis at NSM@standards.org.au.
Here is EMR Australia's submission:
18 July 2016
Ms Jessica Curtis
National Sector Manager
Dear Ms Curtis
Standards and the Future of Distributed Electricity
Thank you for the opportunity to comment on the above discussion paper in regards to how standards can support the diverse possible futures of electricity networks, generation, and consumption.
I submit that the prime function of standards is to support the health and safety of the community. To this end, I offer the following comments.
Distributed energy coordination – metering
There is a trend towards the installation of ‘smart’ meters in Australia. The installation of these meters has been mandatory in Victoria and other states are encouraging the use of these meters. NSW is offering financial incentives for their adoption.
There are a number of problems with the use of ‘smart’ meters.
1. ‘Smart’ meters emit radiofrequency electromagnetic fields which penetrate walls and expose those living within the buildings to which they are attached. As electricity meters are often attached to bedroom walls, it is not uncommon for people’s heads to be in close proximity, for long periods of time, to the meters’ antennas as they transmit radiofrequency signals.
1.1 radiofrequency electromagnetic fields have been classified by the International Agency for Research on Cancer as Class 2B carcinogens. 
1.2 Numerous studies show that low levels of exposure to these fields is associated with adverse biological effects such as changes to neurotransmitters, hormones, cell behaviour, DNA breaks, cancer and brain tumours.
1.3 Many people report adverse symptom that coincide with the activation of smart meter networks in their neighbourhoods – whether or not they were aware that the meters were active. These symptoms are consistent with those reported in the scientific literature from exposure to radiofrequency radiation. 
1.4 The Australian radiofrequency standard does not protect the public from harmful effects of radiation from ‘smart’ meters. It has been designed to protect against instantaneous, acute, heating effects and not the continuous, low-level, long-term biological effects that are of concern with ‘smart’ meters.ARPANSA does not claim that compliance with its standard ensures ‘safety’.
2.Standards-setting bodies and bodies responsible for the installation of ‘smart’ meters need to consider the potential for litigation and compensation costs. Compliance with the ARPANSA standard does not protect against the risk of litigation, as in McDonald and Comcare, Administrative Appeals Tribunal, February 2013. 
3.1 strong community backlash
3.2 fire risks
3.3 ability of utilities to remotely control household electricity
3.4 privacy and security of information about household activities.
Supporting technologies that use radiofrequency electromagnetic fields for communications have the potential to expose householders and neighbours to radiation that has not only not been demonstrated to be safe but is association with harmful biological effects. See point 1 above.
Data - frameworks
The transfer of data by wireless networks – for example wireless communication to and from an inverter – also exposes householders and neighbours to radiofrequency electromagnetic fields – see point 1.
I urge Standards Australia to ensure that standards-setting committees take these issues into consideration and contain an appropriate balance of stakeholders, including members of the community.
 International Agency for Research on Cancer, Monographs on the Evaluation of Carcinogenic Risks to Humans, Volume 80, Non-Ionizing Radiation, Part 1: Static and Extremely Low-Frequency (ELF)
McLean, Lyn, ‘The Force’, Melb, Scribe, 2011
Lamech, F, ‘Self-Reporting of Symptom Development From Exposure to Radiofrequency Fields of Wireless Smart Meters in Victoria, Australia: A Case Series’, Altern Ther Health Med 20(6):28-39, 2014.
 ARPANSA RP3 “Maximum exposure levels to radiofrequency fields – 3 kHz to 300 GHz” Radiation Protection Series 2002.
 Administrative Appeals Tribunal, February 2013, http://www.austlii.edu.au/au/cases/cth/aat/2013/105.html#sthash.z8p1029b.dpuf