Yesterday's column, "PG&E Smart Meter Opt-out: Decision By
Regulators," looked at salient aspects of the California
Public Utilities Commission's proposed decision on PG&E's
application for a smart meter opt-out plan. That decision is
set to be voted on today.
We noted yesterday the CPUC's stance that residential
customers should be able to opt-out "for any reason or for
no reason," its findings that smart meters' RF emissions
fall well within the guidelines set by the Federal
Communications Commission and that opt-outers should pay—but
maybe all ratepayers should pay, too, a zany view yet to be
finalized.
Today, let's dip back into the CPUC's proposed decision for
a closer look at some of the objections to PG&E's suggested
solutions and regulators' takes on those objections.
Here's the link to the CPUC's proposed decision for PG&E and
here's a link to remotely watch and listen to today's
proceedings via a Web link.
First, the opt-out option deemed most feasible by PG&E is
the "radio-off" option, based on smart meters already
installed and those purchased and awaiting deployment.
The Utility Reform Network (TURN) responded that that option
might address radio frequency (RF) emissions and privacy,
but would not resolve concerns about accuracy. (Studies in
California, if I'm not mistaken, have already conclusively
demonstrated the accuracy of smart meters.)
The EMF Safety Network objects to the "radio-off" option
because "there is no assurance that the smart meter is
actually turned off." (No telling what tricks the CPUC and
PG&E might conspire to pull on the citizenry, right?)
Further, the EMF Safety Network, the Ecological Options
Network (EON) and the town of Fairfax, Calif. all seek
community-wide opt-out options. That, of course, is a
double-edged sword.
Frankly, I doubt that everyone in Fairfax, for instance, is
against smart meters and doesn't want access to energy use
data, dynamic pricing and the system-wide benefits that
include a reduction in greenhouse gas emissions. So is it
not somewhat tyrannical to force a community-wide policy?
How will citizens who opt out of opting out be treated?
Secondly, until now it's been necessary to consider the
costs and loss of benefits that individual opt-out decisions
might inflict on an advanced metering infrastructure (AMI)
system. Towns or counties selecting a community-wide opt-out
option might inflict significantly greater damage to
benefits sought and paid for by the vast majority of
residential customers—the same folks who voted for
California's AB32, which in part prompted the state mandate
for smart meters in the first place.
Finally, once political units such as towns and counties
seek a community-wide, opt-out option, it begins to smack
more of political gamesmanship rather than the ostensible
purpose of protecting the health of citizens. Granted, these
communities—or, more likely, their politicians—may feel that
a grandstanding payback is due PG&E for the latter's
heavy-handed tactics in heading off local efforts to secure
the option to municipalize electricity services.
As anyone who has read my diatribes about Xcel Energy and
Boulder, Colo.'s own municipalization effort knows, I'm
against any interference with a community's right to decide
its own future. But declaring war on state policies designed
to defer capital investment, curb greenhouse gas emissions
and offer citizens energy management information and tools
is an inappropriate way to hit back at PG&E and
self-defeating to boot.
The CPUC's proposed decision noted that "there is a great
deal of concern that the radio-off option would not reduce
the level of RF emissions." So the commission sought data on
"both the average duration and the duration of
communications between the electric and gas smart meters
with the utility and the level of RF emissions at those
times." The commission also sought "information comparing
the level of RF emissions from a smart meter with the radio
off [option], from a digital meter with no communications
capability and from an analog meter."
"One of the more controversial disputes" in the opt-out
proceedings was "how many times (average and maximum) an
electric smart meter transmits during a 24-hour period,"
according to the CPUC's proposed decision.
According to PG&E, the cumulative transmission time is 45
seconds per day. Upon examination, the CPUC found, PG&E's
response revealed that total average transmission time was
45 seconds, with a maximum of 15 minutes per day. According
to PG&E's vendor, Silver Spring Network, a typical smart
meter will "communicate" about 45 seconds per day, not 15
minutes. Where the network may not be complete, each meter
may attempt to communicate with the network more often,
resulting in a maximum transmission time of 15 minutes per
day.
This strongly suggests, ironically, that networks—perhaps
incomplete due to holes created by residences that opt-out
of smart meters—actually emit greater RF than complete
networks. So opting out costs all ratepayers in money and
system effectiveness, while raising the level of RF
emissions.
"Other parties," the CPUC noted, have maintained that the RF
transmission by smart meters is constant. More on this
canard in a moment.
In response to a request that the FCC step in and order
removal of smart meters already installed, that agency noted
"the FCC has no data or report to suggest that exposure is
occurring at levels of RF energy that exceed our RF exposure
guidelines. In contrast, the California Council on Science
and Technology recently released a report that found that
'scientific studies have not identified or confirmed
negative health effects from potential non-thermal impacts
of RF emissions such as those produced by existing, common
household electronic devices and smart meters."
Further, the FCC noted, RF emissions by smart meters
"produce exposure of no more than 65 percent of the FCC
limit at the face of the meter when programmed to transmit
continuously. The devices normally transmit for less than
one second a few times each day and consumers are normally
tens of feet or more from the meter face, so the actual
exposures are typically thousands of times less than this
'worse case' measurement condition."
Another issue: do smart meters emit RF emissions when the
meter is not transmitting? The answer: yes. Damning? Not at
all.
The CPUC's proposed decision noted PG&E's statement that
"all digital circuitry—from that contained in clocks, in
stereo equipment or in answering machines—emits de minimus
RF that is governed by FCC limits for unintentional RF
emissions." Values calculated for smart meter certification
compared the emissions in the radio-off and radio out (that
is, no radio) options. The values show that de minimus RF
emissions actually were similar or lower in the radio-off
option and both radio-off and radio out emissions are well
below the FCC's guidelines. PG&E acknowledged that analog
meters emit no RF at all. This, of course, is irrelevant,
since many ubiquitous household devices emit the same level
of RF as a smart meter with the radio turned off.
The CPUC further noted that the FCC's "authority over
technical aspects of radio communications is longstanding
and clear" and its responsibilities include regulating RF
emissions "to protect public health and safety." Further,
the FCC monitors the results of ongoing research in order to
maintain the scientific validity of its standards.
Other objections included Fairfax, Calif.'s contention that
smart meters violated the Americans with Disabilities Act.
Lake County contended that smart meters overburden utility
easements. The CPUC batted down these desperate
distractions, as it should.
The commission went on to note that "in determining the best
opt-out option ... we must balance the concerns expressed by
customers against California's overall energy policy."
The proposed decision reiterated that the opt-out option
should not preclude the collection of interval data that
would support citizens' energy management decisions and
participation in, for instance, dynamic pricing and demand
response programs. Therefore it favored adoption of "a
non-communicating meter—that is, a smart meter with the
radio off or a digital meter with no communications
capability. This option was proposed to enable customers to
take advantage of already deployed energy policies ..."
In the end, however, the CPUC decided that—"in light of
parties' comments on the proposed decision" - that it would
settle for an analog meter opt-out option subject to further
review "to ensure that this option does not impede the full
implementation of net metering, demand response and smart
grid." And the CPUC chose only one opt-out option, rather
than several, for clarity and simplicity of implementation.
I'd have to say, at first blush, that the mob has won a
victory here.
Yet to be decided, in a second phase of this proceeding:
whether community-wide opt-outs should be allowed, and how
the costs incurred by opt-outs should be allocated. I can't
wait to hear more arguments that those who refuse to join an
effort to modernize the grid, defer capital investment in
new power generation and clear the skies and reduce carbon
emissions expect the rest of us to pay for their hobbling of
the system.
It is said that democracy is a messy business. So be it. Let
those who opt-out do so and let them pay the cost, while
ensuring that the electorate's self-imposed goals for
controlling energy costs, pursuing energy sustainability and
lowering energy-related environmental impacts are met.
Dissent is always valuable, but its logic should be
consistent and transparent. Otherwise, we descend into
paralytic bickering and progress towards our society's
chosen goals comes grinding to a halt.
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