Scientific Advice or Reviews Concerning Smart Meter RF Exposure
SPENCER JONES made this Official Information request to Institute of Environmental Science and Research Limited
This request has an unknown status. We're waiting for SPENCER JONES to read a recent response and update the status.
From: SPENCER JONES
Dear Institute of Environmental Science and Research Limited,
Subject: Official Information Act Request – Scientific Advice or Reviews Concerning Smart Meter RF Exposure
Kia ora,
I am making this request under the Official Information Act 1982.
I seek records relating to any scientific advice, reviews, or assessments undertaken or provided by ESR concerning radiofrequency (RF) exposure from electricity smart meters (Advanced Metering Infrastructure – AMI).
Specifically, please provide:
1. Contracted or Advisory Work (since 1 January 2015)
Any:
Contracted research;
Scientific reviews;
Technical reports;
Advisory memoranda;
Risk assessments;
prepared for or provided to any government agency concerning RF exposure from smart meters.
2. Standards and Methodology Review
Any documentation analysing or advising on:
NZS 2772.1:1999;
ICNIRP guidelines;
Time-averaging methodology;
Exposure measurement approaches specific to AMI technology.
3. Inter-Agency Scientific Advice
Any communications between ESR and:
Ministry of Health;
Health NZ;
Electricity Authority;
MBIE;
WorkSafe;
where RF exposure from smart meters was discussed.
4. Absence Confirmation
If no such records exist, please confirm that ESR holds no:
Reviews;
Advisory papers;
Internal analyses;
Commissioned reports;
relating to smart meter RF exposure.
For clarity:
I do not seek speculative or new scientific analysis.
I seek documentary records already created or relied upon.
If this request requires refinement, I am willing to narrow it under section 13.
If any material is withheld under section 9, please identify the subsection relied upon and provide the public interest balancing assessment under section 9(1).
If held electronically, I request electronic copies.
Kind regards,
Spencer Jones
From: OIA & Privacy Requests
Dear Spencer,
I am writing to acknowledge receipt of your request for information dated
Tuesday 24 February 2026.
PHF Science will endeavour to respond to your request as soon as possible
and in any event no later than Tuesday 24 March 2026, being 20 working
days after the day your request was received pursuant to section 15(1) of
the Official Information Act 1982.
If we are unable to respond to your request by Tuesday 24 March 2026 , we
will notify you of an extension of that timeframe.
Kind Regards,
Wendy Chung
Legal Coordinator
[1]www.phfscience.nz
27 Creyke Road, Ilam
Christchurch 8041, New Zealand
PO Box 29181, Christchurch 8540, New Zealand
New Zealand Institute for Public Health and Forensic Science Formerly
ESR – the Institute of Environmental Science and Research
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From: PHF Science External Enquiries <[email address]>
Sent: Tuesday, 24 February 2026 11:07 am
To: OIA & Privacy Requests <OIA&[email address]>
Cc: Wendy Chung <[email address]>
Subject: Fw: Official Information request - Scientific Advice or Reviews
Concerning Smart Meter RF Exposure
Kia ora,
The below request was sent to the External Enquiries mailbox and needs a
response.
If you are not the correct person to respond to this request, please
forward to the appropriate person (with a copy to External Enquiries).
Ngā mihi,
PHF Science External Enquiries
--------------------------------------------------------------------------
From: SPENCER JONES <[FYI request #33832 email]>
Sent: Tuesday, February 24, 2026 10:50
To: PHF Science External Enquiries <[email address]>
Subject: Official Information request - Scientific Advice or Reviews
Concerning Smart Meter RF Exposure
Dear Institute of Environmental Science and Research Limited,
Subject: Official Information Act Request – Scientific Advice or Reviews
Concerning Smart Meter RF Exposure
Kia ora,
I am making this request under the Official Information Act 1982.
I seek records relating to any scientific advice, reviews, or assessments
undertaken or provided by ESR concerning radiofrequency (RF) exposure from
electricity smart meters (Advanced Metering Infrastructure – AMI).
Specifically, please provide:
1. Contracted or Advisory Work (since 1 January 2015)
Any:
Contracted research;
Scientific reviews;
Technical reports;
Advisory memoranda;
Risk assessments;
prepared for or provided to any government agency concerning RF exposure
from smart meters.
2. Standards and Methodology Review
Any documentation analysing or advising on:
NZS 2772.1:1999;
ICNIRP guidelines;
Time-averaging methodology;
Exposure measurement approaches specific to AMI technology.
3. Inter-Agency Scientific Advice
Any communications between ESR and:
Ministry of Health;
Health NZ;
Electricity Authority;
MBIE;
WorkSafe;
where RF exposure from smart meters was discussed.
4. Absence Confirmation
If no such records exist, please confirm that ESR holds no:
Reviews;
Advisory papers;
Internal analyses;
Commissioned reports;
relating to smart meter RF exposure.
For clarity:
I do not seek speculative or new scientific analysis.
I seek documentary records already created or relied upon.
If this request requires refinement, I am willing to narrow it under
section 13.
If any material is withheld under section 9, please identify the
subsection relied upon and provide the public interest balancing
assessment under section 9(1).
If held electronically, I request electronic copies.
Kind regards,
Spencer Jones
-------------------------------------------------------------------
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From: OIA & Privacy Requests
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Good Morning Spencer,
Please find attached, a letter advising of a partial transfer of your OIA
request received by PHF Science on 24 February 2026.
Kind Regards,
Wendy Chung
Legal Coordinator
[1]www.phfscience.nz
27 Creyke Road, Ilam
Christchurch 8041, New Zealand
PO Box 29181, Christchurch 8540, New Zealand
New Zealand Institute for Public Health and Forensic Science Formerly
ESR – the Institute of Environmental Science and Research
References
Visible links
1. http://www.phfscience.nz/
http://www.phfscience.nz/
From: OIA Requests
Kia ora Spencer,
Thank you for your request under the Official Information Act 1982 (the
Act), received by the Ministry of Health - Manatū Hauora on 9 March 2026.
You requested:
"1. Contracted or Advisory Work (since 1 January 2015)
Any:
Contracted research;
Scientific reviews;
Technical reports;
Advisory memoranda;
Risk assessments;
prepared for or provided to any government agency concerning RF exposure
from smart meters.
2. Standards and Methodology Review
Any documentation analysing or advising on:
NZS 2772.1:1999;
ICNIRP guidelines;
Time-averaging methodology;
Exposure measurement approaches specific to AMI technology.
4. Absence Confirmation
If no such records exist, please confirm that ESR holds no:
Reviews;
Advisory papers;
Internal analyses;
Commissioned reports;
relating to smart meter RF exposure."
The reference number for your request is H2026079680. We will endeavour to
respond to your request as soon as possible and in any event no later than
8 April 2026 being 20 working days after the day your request was
received. If we are unable to respond to your request by then, we will
notify you of an extension of that timeframe.
If you have any queries regarding your request, please feel free to
contact the OIA Services Team on [1][email address]. If any
additional factors come to light which are relevant to your request,
please do not hesitate to contact us so that these can be taken into
account.
Under section 28(3) of the Act you have the right to ask the Ombudsman to
review any decisions made under this request. The Ombudsman may be
contacted by email at: [2][email address] or by calling 0800
802 602.
Ngā mihi,
OIA Services Team
Ministry of Health | Manatū Hauora
M[3]inistry of Health information releases
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2. mailto:[email address]
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SPENCER JONES left an annotation ()
Public Annotation, This response is useful because it helps clarify where responsibility for smart meter RF exposure advice appears to sit within government.
PHF Science / ESR has not said that no relevant information exists. Instead, it has transferred parts 1, 2, and 4 of this request to the Ministry of Health under section 14 of the Official Information Act, on the basis that those parts are “more closely connected with the functions of the Ministry of Health.” Those transferred parts cover the core scientific material sought here, including any contracted research, scientific reviews, technical reports, advisory memoranda, risk assessments, and any documentation analysing standards or methodologies such as NZS 2772.1:1999, ICNIRP guidelines, time-averaging methodology, and exposure measurement approaches specific to smart meter / AMI technology.
That is significant. It suggests that, within the present governance structure, the Ministry of Health is regarded as the primary public authority for the underlying scientific and health-risk advice concerning smart meter RF exposure, even where ESR / PHF Science may have had a technical, analytical, or advisory role. In other words, the key documentary record for the substantive scientific justification appears likely to sit with the Ministry rather than with ESR as the responding agency on this thread.
Equally important is what was not transferred. PHF Science / ESR appears to have retained part 3 of the request, namely communications between ESR and other agencies such as the Ministry of Health, Health NZ, the Electricity Authority, MBIE, and WorkSafe where smart meter RF exposure was discussed. That means this thread may still produce an important second category of records: the inter-agency correspondence trail showing how scientific or technical information moved between agencies, and possibly how advice was communicated, interpreted, or relied upon in practice.
For researchers and future requesters, this transfer helps map the decision chain. At least on the face of this response, the Ministry of Health appears to hold the core scientific review and standards-related material, while ESR / PHF Science may hold the communications and cross-agency interaction record. That distinction matters, because it points to a wider governance structure in which scientific advice, health-risk interpretation, and regulatory or policy responses may be distributed across several institutions rather than held in one place.
This thread should therefore now be read in two parts: first, as a live request for ESR / PHF inter-agency communications on smart meter RF exposure; and second, as a pointer that the Ministry of Health is expected to respond on the substantive scientific reviews, standards analysis, and any absence confirmation. The transfer is therefore not merely procedural; it is itself informative, because it identifies where the core RF exposure advice documents are believed to sit.
From: OIA Requests
Tēnā koe Spencer,
Thank you for your request received as a transfer from PHF Science
(formerly ESR) on 9 March 2026.
1. Contracted or Advisory Work (since 1 January 2015)
Any:
· Contracted research;
· Scientific reviews;
· Technical reports;
· Advisory memoranda;
· Risk assessments;
prepared for or provided to any government agency concerning RF exposure
from smart meters.
2. Standards and Methodology Review
Any documentation analysing or advising on:
· NZS 2772.1:1999;
· ICNIRP guidelines;
· Time-averaging methodology;
· Exposure measurement approaches specific to AMI technology.
4. Absence Confirmation
If no such records exist, please confirm that ESR holds no:
· Reviews;
· Advisory papers;
· Internal analyses;
· Commissioned reports;
relating to smart meter RF exposure.
Your request has been refused in full under section 18(g)(i) of the Act,
on the basis that the information requested is not held by the Ministry
and there are no grounds for believing it is held by another agency
subject to the Act.
Under section 28(3) of the Act, you have the right to ask the Ombudsman to
review any decisions made under this request. The Ombudsman may be
contacted by email at: [1][email address] or by calling 0800
802 602.
Ngā mihi,
OIA Services Team
Ministry of Health | Manatū Hauora
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- Add an annotation (to help the requester or others)
- Download a zip file of all correspondence (note: this contains the same information already available above).
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SPENCER JONES left an annotation ()
Public Annotation – Scientific Advice / Reviews Concerning Smart Meter RF Exposure
This request sits within a broader regulatory review concerning smart meter RF exposure, safety oversight, and cross-agency scientific reliance.
Across multiple related OIAs (Electricity Authority, MBIE Energy Safety, ESR, WorkSafe), a recurring structural issue has emerged:
• Agencies frequently rely on high-level compliance statements (e.g., reference to NZS 2772.1 limits),
• Yet documentation of internal scientific evaluation, review processes, or updated reassessment cycles is often unclear or fragmented,
• Cross-agency visibility of scientific advice appears compartmentalised.
This OIA seeks to clarify whether any scientific advice, reviews, technical assessments, or commissioned expert analysis concerning smart meter RF exposure have been held, relied upon, or considered.
This is not a challenge to the existence of NZS 2772.1.
It is an inquiry into whether:
1. Any post-deployment scientific review was conducted;
2. Any reassessment occurred following international developments;
3. Any internal or external expert advice was sought beyond standard compliance references;
4. Any scientific updates were incorporated into regulatory oversight practice.
⸻
Why This Matters (Governance Context)
Within the Mercury Project folder, the regulatory pattern observed includes:
• Reliance on historical compliance standards,
• Deferral to other agencies for scientific matters,
• Limited evidence of integrated cross-agency scientific review.
If no internal scientific review exists, that is material.
If reviews exist but are not centrally collated, that raises search transparency questions.
If scientific advice was commissioned but not retained, that has Public Records Act implications.
The issue is not whether meters comply with NZS 2772.1.
The issue is whether:
• Ongoing scientific scrutiny has been documented,
• Regulatory bodies have periodically reassessed exposure assumptions,
• Scientific developments (including international comparative literature) have been formally considered.
⸻
Pattern Across Prior OIAs
In related smart meter OIAs:
• Some agencies have relied on “information not held” (s18(e)) positions.
• Others have referenced standards without producing underlying evaluative documents.
• Disposal authority boundaries have been invoked to limit retention obligations.
This request therefore tests whether:
• Scientific advice exists within the regulatory ecosystem,
• It has been formally recorded,
• It has been shared across agencies,
• Or whether reliance is primarily derivative (i.e., deferring to ESR or international standards without documented independent review).
⸻
Search Adequacy Expectations
For clarity, a complete response would ideally identify:
• Any briefings referencing RF exposure;
• Any internal technical notes or risk assessments;
• Any commissioned expert advice;
• Any inter-agency correspondence concerning RF scientific issues;
• Any updates post-original smart meter rollout.
If the response relies on s18(e), confirmation of:
• Systems searched,
• Business units consulted,
• Date parameters applied,
would assist transparency.
⸻
Broader Regulatory Architecture Context
This request also connects to ongoing work mapping:
• Electricity Authority market oversight,
• MBIE Energy Safety technical jurisdiction,
• ESR scientific reference roles,
• WorkSafe safety enforcement boundaries,
• Utility provider (Mercury) operational practices.
Understanding whether scientific advice has been documented within this network is central to assessing:
• Whether oversight is active or passive,
• Whether reliance on historical standards is periodically reassessed,
• Whether public-facing assurances reflect documented review processes.
⸻
Procedural Position
I will assess the response against:
• Existence of documented scientific review,
• Transparency of search methodology,
• Cross-agency coordination evidence,
• Any withholding grounds cited.
This annotation records the governance purpose of the request and the evaluation criteria that will be applied once the response is received.
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