by David Sheldon
In its Order of January 12th the Michigan Public Service Commission ordered each of the privately owned electric utilities operating in the State of Michigan to respond by March 16th, 2012 to a series of questions put by the Commission concerning their plans for ‘smart’ meter deployment, the costs and benefits of such deployment, and any plans they had for allowing customers to opt-out. Many utilities responded, but the subject of this article will be the response filed by the Detroit Edison company through its attorney.
What follows are nearly all of the key assertions in Detroit Edison’s response, and after each a statement of what the actual facts are as known to credible experts in the industry. I leave it to the reader to determine whether this utility company has been forthcoming in its responses to the Commission.
(1) DTE Assertion: “The use and deployment of smart meters in Edison’s service territory is safe …”
FACT: Nearly every independent study, not financed by the utility industry, has found that the type of radio waves broadcast by the smart meters, at levels far lower than FCC standards, to be suspect as a long range cause in a whole range of illnesses affecting the public at large, and as an immediate threat to a small minority of individuals who are electro-sensitive. What DTE apparently means by its response is merely that its smart meters are legal because they comply with an obsolete FCC standard based on thermal effects alone.
The information DTE presents as to the safety of non thermal levels of radiation comes entirely from the manufacturer of the meters (Itron) or from one of the trade associations to which most utilities belong.
(2) DTE Assertion: “The use and deployment of smart meters … provides important benefits to the reliability and operation of the electric system …”
FACT: (1) On the plus side: the only benefits Edison has ever identified for reliability of the system are (a) faster outage detection, and (b) the ability to shift some peak demand to off peak hours through the use of either “time of use pricing” or a demand response system wherein Edison can send signals to turn off individual appliances in homes that have volunteered to participate. The peak shifting benefit however depends on customer’s voluntary choice to participate, and, in the case of demand-response, on the customer making an investment in smart appliances. This benefit does not follow from the mere installation of smart meters. Also, if DTE ever did any research to find how many of its customers would volunteer for demand-response or time-of-use, it has not provided the results of any such research to buttress its case.
(2) On the minus side: A wide range of security experts have weighed in that the ‘smart grid’ will make us more vulnerable than ever to having the entire power grid brought down by hackers or terrorists. “The vulnerability of the energy industry’s new wireless smart grid will inevitably lead to lights out for everyone,” according to leading cyber expert David Chalk.
In a recent interview on energyNow! Former CIA Director James Woolsey offered this opinion of the ‘smart grid’:
“They’re constructing a smart grid that will make it easier for you or me to call our homes on our cell phones and turn down our air conditioner on a hot afternoon. But that may well mean that a hacker in Shanghai can do the same thing with his cell phone, or worse. The so-called smart grid that’s as vulnerable as what we’ve got is not smart at all. It’s a really, really stupid grid.”
DTE Assertion: That a DOE grant will cover one half the cost of the first 600,000 smart meters only, and that DTE intends to install 2.6 million electric meters. DTE makes no mention in its filing where the rest of the money is to come from, but has been telling its customers that they are not paying for it.
FACT: A recent Court of Appeals decision held that $37 million dollars that had been allowed by MPSC as a charge back to customers was improper. This tells us where the rest of the money was going to come from and shows DTE’s claims in this regard to be false.
DTE Assertion: The company presents a laundry list of hypothetical benefits in support of its smart meter deployment. It makes no attempt to quantify these benefits in dollar terms or to show that the benefits will outweigh the costs to utility customers.
FACT: The Commission had asked each electric utility to supply an “estimate of the savings to be achieved by the deployment of smart meters.”
DTE Assertion: “Due to the elimination of estimates and the accurate reads, customer complaints in the areas where AMI is installed have fallen off dramatically.”
FACT: DTE presents no data in support of this claim. In fact, to the casual observer, it would seem that customer complaints about skyrocketing bills have gone off the charts since smart meters have been installed. This has been the case in other states and we are starting to see enough instances of it here in Michigan that the burden should be on DTE to present data to show that all the highly public complaints are the exception and not the rule.
DTE Assertion: Edison has installed over 650,000 AMI smart meters without a single OSHA safety event.
FACT: DTE has presented no data to back up this assertion, which many would find a laughable assertion in view of all the stories of house fires, burned out meter sockets and the like in every state where these have been installed. The company surely has some OSHA events in its overall operations and could choose to submit copies of its OSHA reports to back up this contention.
DTE Assertion: “Gains in Customer Satisfaction are at the forefront of the non-monetary benefits”
FACT: DTE submits nothing to substantiate this point and the overwhelming body of evidence is to the contrary.
DTE Assertion: “Customers will be able to view their daily and hourly energy usage through our secure online system. They can use this data to help make informed decisions regarding energy usage and to assist them in their energy conservation efforts.
FACT: DTE does not provide any illustration of what an hourly based display of energy usage might look like to the customer. In fact such an energy use display would be confusing to the utility customer because so many different appliances would be aggregated into the totals that the customer could not make any sense out of which appliances were responsible for the totals or which appliances could be used less or scheduled at a different hour in order to make the totals better. In order for a really useful display to be provided DTE would have to record usage in a much more fine grained manner, for example one minute intervals, and then identify the signatures of individual appliances and label the display to show the start and stop of each individual appliance. But to do this would contradict all the data the company presents elsewhere on the total amount of radiation the meters transmit in a 24 hour day.
DTE Assertion: In response to the Commission’s Order that utilities furnish “Any scientific information known to the electric utility that bears on the safety of the smart meters to be deployed …”, DTE responds with a statement that begins with “Edison believes that AMI smart meters are safe and have been thoroughly studied.”
FACT: The utilities were not asked to state their beliefs – they were asked to supply “any scientific information” known to them. Has DTE complied? Can it really be the case that this utility has no knowledge of:
(1) The American Academy of Environmental Medicine’s recommendation to the California PUC that smart meters are a hazard and that their deployment should be stopped?
(2) The Hirsch report – which shows the intensity of the RF exposure from smart meters is much higher than from other commonly used devices?
(3) The Sage Report – which shows, among other things, that even the thermal limits prescribed by the FCC are being exceeded in multi bank apartment buildings?
(4) The Greek research which shows the effect of non-thermal radiation on mouse brains?
(5) The Bio-Initiative Report?
(6) The Swedish study by Ole Johansson on disturbances to the immune system by electromagnetic fields?
If DTE has no knowledge of any of this body of research then they have answered the Commission’s Order in a truthful manner. But if they have no knowledge of any of this research then how are they competent to conduct an experiment on millions of Michigan citizens?
If they do have such knowledge then they have not responded honestly. The Commission’s Order put a burden on them to be forthcoming and there should be a burden on them to explain why all of this research is not relevant, and only the research done by Itron and the utility trade associations is relevant.
DTE Assertion: “The RF emissions from an AMI smart meter are similar to that emitted by a remote control or garage door opener device that is used often in everyday life …
FACT: The RF emissions from an AMI smart meter are NOT similar to that of a remote control or garage door opener in that those devices do NOT subject the users to constant radiation on a 24/7/365 basis! Moreover remote controls and garage door openers are devices which people choose on a voluntary basis – so that those who might be electro-sensitive can avoid them altogether.
DTE Assertion: “At no time will any customer specific data, like addresses, phone number, account status or social security numbers be transmitted by the AMI meter or gas module”.
FACT: This statement evades the reality – which is that a number identifying the meter is transmitted – and that meter number, for a skilled hacker, is the key to get all the rest.
DTE Assertion: “The data collected from a AMI smart meter is the same data that is collected from an analog meter.” and “ The data collected from the AMI smart meter is energy use for the entire customer location and not data on individual appliances and devices.”
FACT: This is about as far from the truth as one can imagine. Each appliance in the home has a ‘signature’ based on the amount of current it draws, the inrush current, the duration and the amount of phase shift. The utility will have a library of such ‘signatures’ that it can use to interpret the data coming from an individual smart meter. It will be possible to determine with certainty which appliances are running and when. In California the PUC has even given their utilities permission to sell this data to third parties. Companies are lining up to profit from this data and software already exists to efficiently convert all the home meter charts into appliance use charts.
DTE Assertion: “The overwhelming majority of our customers fully support AMI”
FACT: Absolutely no evidence has been offered by DTE to support this claim. We are not aware of any market research being done to establish homeowner attitudes. In any case the overwhelming majority of the public does not even know what has been done to them. The company has not seen fit to educate its customers as to the pros and cons of their program.
Those utility customers who have taken the time to educate themselves have almost universally rejected the program – as is evident from over 400 complaints filed on the MPSC’s own website.
DTE Assertion: With regard to persons opting out of smart meters ‘ “their lack of participation will reduce the benefits of AMI for all customers …”
FACT: No evidence has been supplied to support this claim. If the supposed benefit of AMI to the customer is that he can understand his usage better and make decisions to conserve – how would such a benefit be impacted in any way by his neighbor’s decision not to participate?
DTE Assertion: “The Company should be made whole for all incremental costs, the electing customers should bear the costs, and the opt out charges should be based on costs consistent with the provisions of PA 286, M.C.L. 460,6”
FACT: The cited public act cuts both ways. If it is not lawful under the Act for customers not opting out to bear costs properly attributable to the opt-out customers, then the reverse should also be true: Customers choosing to opt-out should not be charged any of the costs needed to provide AMI service to the class of customers who want and choose to retain that service!
DTE Assertion: “The opt-out program shall not operate in a manner that contradicts or unreasonably interferes with the AMI benefits enjoyed by all other customers …”
FACT: (1) The opt-out customers are arguing that they have a constitutional right under the 4th Amendment to the U.S. Constitution, to protect the privacy of their homes. That right does not yield and must never yield to the desire of some other customers to enjoy “AMI benefits” that are not an essential aspect of a regulated monopoly service provider.
(2) The whole basis of utility regulation of a monopoly public service provider is that the monopoly provide only that service which must be provided on a monopoly basis, leaving it to the free market to supply customer’s desires for bells and whistles.
DTE Assertion: “Opt-out decisions must be initiated and made by individual customers and not by broader interest groups or municipalities on their behalf. Opting out will … subject the customer to additional charges, so permitting third party’s to make this selection is inappropriate.”
FACT: Allowing municipalities to opt-out, or to create certain neighborhoods within their cities that have no smart meters, would allow for the creation of safe havens for the electro-sensitive minority in the population. Without community opt-out there could be no safe havens. Individual opt-out alone will never solve the problem for the electro-sensitive, because they will still be bombarded with RF radiation from their immediate neighbors on all sides. For the same reason individual opt-out will not solve the problem for those of us who are NOT electro-sensitive but wish to take the precaution of living in an area free of smart meter radiation in order to protect our long run health!
Even if it were true that a community opt-out would subject all in that neighborhood to additional costs (a fact not yet established), people still have freedom of choice when it comes to picking a city or a neighborhood in which to live. Those who are electro-sensitive will gravitate toward neighborhoods where they may enjoy some protection and may well choose to bear any increased costs that are necessary – though it seems more likely their cost of electricity should be less since the utility will avoid all manner of expenses for installing smart meters in those areas, maintaining wireless systems in those areas, and so forth. Those who want the benefits of smart meters or wish to avoid any opt-out costs can choose other neighborhoods in which to live.
In our society we choose to provide all sorts of accommodations for people with various disabilities. We provide handicapped parking spots, curb cuts for wheelchairs, handicapped bathroom and so on. I think most of us accept any inconvenience these accommodations may cause us because we recognize the value of allowing people who are challenged in various ways to enjoy a fuller participation in society. It is just and it allows society to benefit from their talents.
Being electro-sensitive is a recognized disability like any of these others. We should seek to make it possible for such people to live among us and to fully participate in our economic and social life. We should seek, moreover, to make it possible for there to be safe havens for those who simply want to be prudent about their long run health risks!
DTE Assertion: “Edison intends to file its op-out program to address specific details as part of its next general rate filing.”
MY RESPONSE: It is time for DTE to file a specific opt-out plan NOW. This controversy has gone on for a year or more already. It is time. DTE is playing a game to get as many meters installed as possible before the MSPC makes any decision on opt-outs.
The Michigan Public Service Commission owes it to the public it serves to impose an immediate moratorium on any more smart meter installs until such time as the opt-out issue has been resolved and an objective study of the health risks has been completed.