Thursday, December 4, 2008

W.E.E.P. submission to the Notice of Proposal to Amend a Code

Ground current electricity, also known as 'stray voltage' is a very serious and dangerous pollution problem throughout North America and other locations around the globe. The letter below was submitted by WEEP in response to a proposal to amend the Ontario Electrical Distribution Code.


Martin Weatherall Co-Director
W.E.E.P. – Wireless Electrical and Electromagnetic Pollution
R.R. #3
Bright, Ontario
N0J 1B0

December 2, 2008

The Ontario Energy Board

Farm Stray Voltage Consultations

Dear O.E.B.:

This letter serves as the W.E.E.P. submission to the Notice of Proposal to Amend a Code, Proposed Amendments to the Distribution System Code Board file # EB-207-0709.

While the Proposal to Amend a Code appears to offer some improvements to the code for the safety of livestock, the OEB will fail with this submission to correct the real problem that is facing Ontario. I refer to the fact that Ontario has a dangerous and outdated electrical distribution system. If this problem is not addressed, serious adverse effects to Ontario livestock, citizens, and the environment will continue to occur. The failure to direct utility companies to correct their distribution systems is improper conduct by the OEB, which contravenes its mandate and may be illegal.

From the beginning, the OEB has chosen to limit the definition of farm stray voltage, excluding all farms except those where the livestock are experiencing problems. In doing so, you have misrepresented the directive of Dwight Duncan, Minister of Energy, in his Order in Council. The directive states that "it is desirable to improve the quality of electricity service to address certain issues related to stray voltage which are currently being experienced by the agricultural sector and, in particular, by farm customers". It is clear from his statement that he is referring to ALL farm customers.

From the time that MPP Maria Van Bommel introduced the private members bill and Minister Dwight Duncan introduced his directive to the OEB, I believed that the farm stray voltage issue would be rectified. I also believed that this change would enable me to return to my farm home, where high levels of stray voltage/ground current had been measured, and live there safely without suffering from the ill health effects from which I had been suffering. My farm, however, did not have livestock, and so did not qualify according to the OEB misinterpretation of the Order. The fact that I did not have livestock did not, however, make the stray voltage/ground current measured inside my home any less real. Nor was the extreme illness that I suffered because of this strong current, mitigated in any way because I did not have livestock. I can assure you that the cancer that I suffered, probably as a result of stray voltage, and the need to move from my affected home would have been equally real whether or not livestock were present on the farm. Yet, somehow, the OEB has discounted my health and the safety of my home, making them less important than that of livestock. If mine were an isolated case, this may not be important. The OEB knows, however, that it is not. This blatant disregard for the health and welfare of rural citizens is an affront and creates for them a danger that they should not have to face.

For this reason, the definition provided in Appendix A, 4.7.1, bullet 3 is unacceptable. Within this section, you mention only customers engaged in livestock husbandry and refer only to livestock making contact with farm stray voltage. Your definition does not recognize that any rural customer can be affected by stray voltage. It also does not recognize that if livestock is in contact with stray voltage, than the humans who tend the livestock must also be in contact with it. Knowing that the voltage is harmful to the livestock, it is reasonable to suppose that it is also harmful to the humans. In addition, you do not recognize that the stray voltage problem on a farm may be worse in the residence than in the barns. Its presence in a home can cause illness, cancer, even death. The health of the farmer is critical to the success of the farm. Without his or her good health, the entire operation can be in serious jeopardy. The OEB has failed to address these very important health and safety issues, and this mistake must be addressed before implementing the proposal.

Another problem with the OEB proposal is that it fails to respond to the Minister's statement that "it is desirable to improve the quality of electricity service in order to address certain issues related to stray voltage". There is nothing in this proposal that helps to improve the quality of service. Instead, there are cheap shortcuts. With this proposal, the utility will endeavour to rectify the worst of a problem at a farm where the problem has been identified (provided the farm has livestock). But, the solution of the problem at one property may become the source of a problem at a neighbouring property. In other words, the OEB will be allowing the utility companies to play a high stakes game of passing the stray voltage problem around the farming community. In the process, the voltage will undoubtedly pass to farms that do not qualify for assistance because they are non-livestock properties. Ultimately, the OEB will be responsible for their difficulties.

And, since most people do not realize that they have a stray voltage problem in their homes until their health deteriorates and they search for answers, it may be too late for them to return to a normal life. Unless the OEB mandates that the electrical utility companies must test all homes and farm properties on a regular basis to ensure that stray voltage is not harming people and livestock, there will most certainly be further victims throughout the province. The proposed "cheap" low cost of dealing with farm stray voltage issues does not rectify the underlying cause of the problem and will not make it go away. Very simply, the utility companies must update and upgrade their distribution systems to correct the problems.

Another important issue for this proposal is high frequency pollution carried by stray voltage. Several submissions, including mine, brought this to the attention of the OEB. Yet, there is no mention within the proposed amendments about the importance and the danger of this high frequency pollution. The difference between one volt of clean stray voltage and one volt of stray voltage carrying dangerous high frequencies has huge health implications for animals and humans and must be addressed by the OEB. If the OEB, its consultants, and the electrical utility companies do not understand the significance of high frequency pollution, they should seek the advice of experts who are knowledgeable about these huge dangers before they endeavour to change the legislation.

The Order from the Minister of Energy combined with the input of many victim farmers and the submissions of interested persons provided the OEB with the information and opportunity to make real and important changes for a safer future. With this proposal, the OEB is very close to making the huge mistake of giving cost considerations more importance than the safety of the electrical distribution system. Please do not leave livestock and people throughout the province in danger by continuing with this inadequate proposal. Please take your duties and responsibilities seriously and make the amendments necessary to help Ontario, rather than allowing stray voltage harm to continue.

Yours truly,

Martin Weatherall

Co-director WEEP – Wireless Electrical and Electromagnetic Pollution