Item #52

Transcription

Item #52

SANTA CRUZ COUNTY
BOARD OF SUPERVISORS INDEX SHEET
Source Code:
9/8/10
COUNC
Agenda Date:
9/14/10
I NVENUM:
64344
Creation Date:
Resolution(s):
Ordinance(s): 5074
Contract(s):
Continue Date(s):
Index: --Letter of County Counsel, dated September 8,2010, with attachments
--Proposed ordinance
Item: 52. CONSIDERED report of County Counsel outlining various options regarding PG&
E's SmartMeter technology, including a temporary moratorium on the installation of
additional SmartMeters;
The Board of Supervisors took the following actions:
(1) Directed staff to investigate whether County right-of-way investments by PG&E
in support of SmartMeter technology have been properly accounted for by PG&E in
calculating the County's franchise fee;
(2) Authorized the Chair to communicate with and support Assemblymember
Huffman's investigation into the potential health impacts of this technology;
(3) Authorized the Chair to write to PG&E requesting meaningful community
meetings at which the public can have their questions answered;
(4) Asked the Legislature, through the County's Legislative Program, to launch a
thorough investigation into the environmental and health effects of this technology;
(5) Authorized the Chair to write to the CPUC (California Public Utility Commission)
requesting a response to the San Jose Mercury News story of September 7,2010,
regarding SmartMeters interference with common household devices; and
(6) ADOPTED ORDINANCE NO. 5074 as an urgency ordinance imposing a
moratorium on the installation of SmartMeters in the unincorporated area of the
County, to remain in effect until December 31, 2010, unless repealed by the Board
of Supervisors
0427
COUNTY OF SANTA CRUZ
OFFICE OF THE COUNTY COUNSEL
701 OCEAN STREET, SUITE 505, SANTA CRUZ, CA 95060-4068 (831) 454-2040 FAX: (831) 454-2115
DANA McRAE, COUNTY COUNSEL
RAHN GARCIA, CHIEF DEPUl
Assistants
Marie Costa
Jane M. Scott
Special Counsel
Tamyra Rice Jason M. Heath Betsy L. Allen Jessica c. Espinoza Dwight L. Herr
Shannon M. Sullvan Christopher R. Cheleden David Brick Sharon Carey-Stronck
September 8, 2010
Agenda: September 14, 2010
Board of Supervisors
County of Santa Cruz
701 Ocean Street, Room 500
Santa Cruz, CA 95060
Re: PG&E Smartmeters 11
Dear Members of the Board:
Your Board directed this office to return today with a status report on
PG&E's SmartMeter™ program and to present options your Board may have
to ensure that PG&E's SmartMeter™ program does not adversely impact the
residents of Santa Cruz County.
As your Board is aware, the California Public Utility Commission (CPUC)
authorized PG&E to fully deploy an Advanced Meter Infrastructure (AMI)
Project within PG&E's territory. This project came to be known as the
SmartMeter™ Program. SmartMeter™ installations began in 2007. By the
fall of 2009, the CPUC had received hundreds of complaints from consumers
about steep increases in their PG&E bills. In response, the CPUC contracted
with Structure Consulting Group for an independent report on the billing
accuracy of PG&E's residential SmartMeters™. Around the same time,
various cities and counties began calling upon the CPUC to suspend PG&E's
SmartMeter™ Program pending the conclusion of the work by the Structure
Group. The CPUC and an administrative law judge assigned to adjudicate a
petition filed by the City and County of San Francisco and joined by your
Board and every city in the County, have yet to rule.
The Structure Group issued its 41S-page report on September 2, 2010.
The entire report is available on the CPUC's website, www.cpuc.ca.gov but
the executive summary is attached to this letter for your convenience. The
report concludes that:
OveralL, Structure found that the AMI technology deployed by
PG&E appears to be 1) consistent with industry standards, based
upon the goals of the AMI implementation and upgrades approved
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by the CPUC, and 2) accurate from a metering and billing
perspective. Structure identified gaps in Customer services and
processes related to high bill complaints, and determined certain
PG&E practices to be partially non-compliant relative to industry
best practices.
In addition to concerns raised about the accuracy of this technology, many
residents are concerned about the potential health impacts of the
SmartMeters™, which emit electromagnetic radiation. In response to
concerns raised in his District, Assemblymember Jared Huffman has called for
an independent agency to study the health effects of SmartMeters™. The
California Council on Science and Technology has been asked to determine
whether the Federal Communications Commission standards for
SmartMeters™ are sufficiently protective when taking into account current
exposure levels to radio frequency and electromagnetic fields. The Councils
report is expected on or about October 14, 2010.
Most recently, concerns have been raised about SmartMeters™ interfering
with the proper functioning of common household devices like wireless
phones, baby monitors and satellite television. Attached for your review is an
article from the San Jose Mercury News dated September 7, 2010, on this
topic.
Within Santa Cruz County, PG&E has completed its infrastructure construction
to support this new technology that included installing antennas on utility
poles in the County rights-of-way pursuant to the County's franchise
agreement. Such an investment in the rights-of-way may trigger an increase
in the franchise fee PG&E pays annually to the County. The County should
take steps to ensure that PG&E is properly accounting for their investment in
the rights-of-way.
There are several options available to your Board to make known your
concerns about PG&E's SmartMeter™ Program and to attempt to preserve
the status quo until more information is available. For example, your Board
could:
. Direct staff to investigate whether County right-of-way
investments by PG&E in support of SmartMeter™ technology have been
properly accounted for by PG&E in calculating the County's franchise fee;
. Authorize the Chair to communicate with and support
Assemblymember Huffman's investigation into the potential health impacts
of this technology;
. Authorize the Chair to write to PG&E requesting meaningful
community meetings at which the public can have their questions answered;
. Ask the Legislature, through the County's Legislative Program,
to launch a thorough investigation into the environmental and health effects
of this technology;
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. Authorize the Chair to write to the CPUC requesting a response
to the San Jose Mercury News story of September 7, 2010, regarding
SmartMetersr™ interference with common household devices; and
. Consider passing an urgency ordinance, by
a four-fifths vote,
imposing a moratorium on the installation of SmartMeters™ in
the unincorporated area of the County. A draft urgency ordinance is attached
for your Board's consideration. If adopted, the urgency ordinance will stay in
effect until December 31, 2010, unless repealed by your Board.
RECOMMENDED:
~'~O\~ ~c7~
County Administrative Officer
DANA McRAE
COUNTY COUNSEL
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ORDINANCE NO. 5074
AN UNCODIFIED ORDINANCE OF THE COUNTY OF SANTA CRUZ
ADOPTED AS AN URGENCY MEASURE IMPOSING A TEMPORAY
MORATORIUM ON THE INSTALLATION OF SMARTMETERS AND
RELATED EQUIPMENT IN, ALONG, ACROSS, UPON, UNDER AND
OVER THE PUBLIC STREETS AND OTHER PLACES WITHIN THE
UNINCORPORATED ARA OF SANTA CRUZ COUNTY
The Board of Supervisors of the County of Santa Cru find as follows:
WHEREAS, the County of Santa Cru (the "County"), through its police
powers granted by Aricle XI of the Californa Constitution, retains broad
discretion to legislate for public purposes and for the general welfare, including
but not limited to matters of public health, safety and consumer protection; and
WHEREAS, the County of Santa Cru has a franchise agreement with
PG&E that has been in effect since 1955; and
WHEREAS, in addition, the County retains authority under Aricle XII,
Section 8 of the Constitution to grant franchises for public utilities, and pursuant to
Californa Public Utilities Code section 6203, "may in such a franchise impose
such other and additional terms and conditions..", whether governental or
contractual in character, as in the judgment of the legislative body are to the public
interest;" and
WHEREAS, Public Utilities Code section 2902 reserves the County's right
to supervise and regulate public utilties in matters affecting the health,
convenience and safety of the general public, "such as the use and repair of public
the poles, wires, mains, or conduits of
any public utilty, on, under, or above any public streets, and the speed of common
streets by any public utilty, the location of
carrers operating within the limits of the muncipal corporation;" and
WHEREAS, Pacific Gas & Electrc Company ("PG&E") is now installing
SmartMeters in Central and Nortern Californa and is installing these meters
withi the County of Santa Cru; and
WHEREAS, concerns about the impact and accuracy of SmartMeters have
been raised nationwide, leading the Marland Public Service Commission to deny
permssion on June 21, 20 1 0 for the deployment of SmarMeters in that state. The
Hawaii Public Utility Commssion also recently declined to adopt a smart
grd system in that state. The CPUC curently has pending before it a petition from
and County of San Francisco, and other muncipalities, seeking to delay
State of
the City
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the implementation of SmarMeters until the questions about their accuracy can be
evaluated; and
WHEREAS, major problems and deficiencies with SmartMeters in
Californa have been brought to the attention of the Board of Supervisors of the
Santa Cruz, including PG&E's confirmation that SmartMeters have
provided incorrect readings costing ratepayers untold thousands of dollars in
overcharges and PG&E' s records outlined "risks" and "issues" including an
ongoing inability to recover real-time data because of faulty hardware originating
with PG&E vendors; and
County of
WHEREAS, the ebb and flow of gas and electrcity into homes discloses
detailed information about private details of daily life. Energy usage data,
measured moment by moment, allows the reconstruction of a household's
activities: when people wake up, when they come home, when they go on
vacation, and even when they tae a hot bath. Smarteters represent a new form
of technology that relays detailed hitherto confidential information reflecting the
times and amounts of the use of electrical power without adequately protecting
that data from being accessed by unauthorized persons or entities and as such pose
utility customers' privacy rights and security interests.
Indeed, the fact that the CPUC has not established safeguards for privacy in its
an unreasonable intrsion of
regulatory approvals may violate the priciples set fort by the U.S. Supreme
Cour in
Kyllo v. United States (2001),533 U.S. 27; and
WHEREAS, significant health questions have been raised concerng the
increased electromagnetic frequency radiation (EMF) emitted by the wireless
technology in Smarteters, which wil be in every house, aparment and business,
thereby adding additional man-made EMF to our environment around the clock to
the already existing EMF from utility poles, individual meters and telephone
poles; and
WHEREAS, FCC safety standards do not exist for chronic long-term
exposure to EMF or from multiple sources, and reported adverse health effects
from electromagnetic pollution include sleep disorders, irritability, short term
memory loss, headaches, aniety, nausea, DNA break, abnormal cell growt,
untested technology, international
scientists, environmental agencies, advocacy groups and doctors are calling for the
use of caution in wireless technologies; and
cancer, prematue aging, etc. Because of
WHEREAS, the primary justification given for the SmarMeters program
is the assertion that it wil encourage customers to move some of their electrcity
usage from daytime to evening hours; however, PG&E has conducted no actual
pilot projects to determine whether ths assumption is in fact correct. Non-
transmitting time-of-day meters are already available for customers who desire
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them, and enhanced customer education is a viable non-technological alternative
to encourage electrcity use timeshifting. Furher, some engineers and energy
conservation experts believe that the SmartMeters program--in totality--could well
actually increase total electrcity consumption and therefore the carbon footprint;
and
WHEREAS, Assembly member Jared Huffman has requested the
Californa Council on Science and Technology to advise him on whether the
Federal Communcations Commssion's standards for SmarMeters are
sufficiently protective and assess whether additional technology-specific standards
are needed for SmartMeters; and
WHEREAS, a response to Assembly member Huffman from the Council
November 1, 2010; and
on Science and Technology is expected as early as
WHEREAS, because the potential risks to the health, safety and welfare of
County residents are so great, the Board of Supervisors wishes to adopt a
moratorium on the installation of Smareters and related equipment withn the
uncorporated area of the County of Santa Cruz. The moratorium period wil
allow the CPUC petition process referenced above to be completed and for
additional information to be collected and analyzed regarding potential problems
with SmarMeters; and
WHEREAS, there is a current and immediate theat to public health, safety
and welfare because, without ths urgency ordinance, SmarMeters or supporting
equipment wil be installed or constrcted or modified in the County without
PG&E's complying with the CPUC process for consultation with the local
jursdiction, the County's Code requirements, and subjecting residents of Santa
Cru County to the privacy, securty, health, accuracy and consumer fraud risks of
the unproven SmartMeter technology; and
WHEREAS, the Board of Supervisors hereby finds that it can be seen with
certainty that there is no possibilty that the adoption and implementation of ths
Ordinance may have a signficant effect on the environment. This Ordinance does
not authorize constrction or installation of any facilities and, in fact, imposes
greater restrictions on such constrction and installation in order to protect the
public health, safety and general welfare. This Ordiance is therefore exempt
from the environmental review requirements of the Californa Environmental
the Californa
Code of Regulations.
Title 14 of
Quality Act (CEQA) pursuant to Section 15061(b)(3) of
WHEREAS, there is no feasible alternative to satisfactorily study the
potential impact identified above as well or better with a less burdensome or
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restrctive effect than the adoption of this interim urgency moratorium ordinance;
and
WHEREAS, based on the foregoing it is in the best interest of public
health, safety and welfare to allow adequate study of the impacts resulting from
the SmartMeter technology; therefore it is appropriate to adopt a temporary
moratorium that would remain in effect from the date of its adoption until
December 31, 2010, uness your Board acts to repeal it prior to that date.
NOW, THEREFORE BE IT ORDAINED by the Board of Supervisors of
the County of Santa Cru as follows:
I
SECTION
Moratorium. From and after the effective date of ths Ordinance, no
SmarMeter may be installed in or on any home, aparent, condominium or
business of any type withn the unincorporated area of the County of Santa Cru,
and no equipment related to SmarMeters may be installed in, on, under, or above
any public street or public right of way withi the uncorporated area of the
County of Santa Cru
II
SECTION
Violations of the Moratorium may be charged as infractions or
misdemeanors as set fort in Chapter 1.12 of the Santa Cru County Code. In
addition, violations shall be deemed public nuisances, with enforcement by
injunction or any other remedy authorized by law.
III
SECTION
This Board of Supervisors finds and determnes that: (a) there is a curent
and imediate threat to the public peace, health, or safety; (b) the moratorium
must be imposed in order to protect and preserve the public interest, health, safety,
comfort and convenience and to preserve the public welfare; and (c) it is necessary
to preserve the public health and safety of all residents or landowners adjacent to
such uses as are affected by ths interim ordiance as well as to protect all of the
citizens of Santa Cru County by preserving and improving the aesthetic and
economic conditions of the County.
IV
SECTION
If any provision of ths interim ordinance is held to be unconstitutional, it is
the intent of the Board of Supervisors that such portions of such ordinance be
severable from the remainder and the remainder be given full force and effect.
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V
SECTION
This interim ordinance is not subj ect to the Californa Environmental
Quality Act (CEQA) pursuant to Section l5060(c) (2) - the activity wil not result
in a diect or reasonably foreseeable indirect physical change in the environment
and Section 15060(c) (3) - the activity is not a project as defined in Section 15378
of the CEQA Guidelines, because it has no potential for resulting in physical
change to the environment, directly or indirectly.
IV
SECTION
Effective Dates. This ordinance shall take effect immediately based on the
findigs by the Board of Supervisors that ths ordinance is necessar for the
protection of the public health, safety, and general welfare. This ordinance shall
be in full force and effect from the date of its adoption by the Board of Supervisors
until December 31,2010, at which time it's terms and provision shall expire and
no longer remain in effect.
of September ,2010, by
PASSED AND ADOPTED THIS 14th day
the Board of Supervisors of the County of Santa Cruz by the following vote:
AYES:
NOES:
ABSENT:
ABSTAIN:
SUPERVISORS Coonerty, Leopold, Pirie, Stone & Campos
SUPERVISORS None
SUPERVISORS None
SUPERVISORS None
TONY
CAMPOS
Chairerson of the Board of Supervisors
AtteslESS, ATGÐ"
Clerk of the Board
~M:?~
County Counsel ..
5
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PG&E Advanced Metering Assessment
Report
Commissioned by the
California Public Utilities Commission
Prepared and Presented by Structure Consulting Group, LLC.
~ Structure™
ATTACHMENtL. Page~of ~ t
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12335 Kíngsríde, #401
&Z Structure™
Houston. TX 77024
Voice: 713.7830500
Fax: 832482.0871
September 2, 2010
Ms. Julie Fitch, Director
Energy Division
Dear Ms. Fitch:
We are pleased to present our final report, "PG&E Advanced Metering Assessment", focused on Smart Meter
accuracy and Customer High Bill Complaints as contracted for by the California Public Utilities Commission on
April1, 2010, and completed on September 2, 2010.
Sincerely,
Stacey Wood
Principal
The Structure Group
Copyright
2010. Confidential and Proprietary to Structure Consulting Group, LLC.
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~ Structure™
PG&E Advanced Metering Assessment Report
Commissioned by the
California Public Utiities Commission
Structure Consulting Group Overview
Structure Consulting Group, LLC ("Structure"), is a global consulting firm focused exclusively on the energy
and utility industry, providing services and technology solutions in North America and Europe. Since opening
the doors in 1998, Structure has served over 100 organizations through all stages of business transformation,
from the beginning of wholesale energy markets to the Smart Grid revolution.
Structure focuses in providing a spectrum of services across business advisory, program management,
solution delivery and implementation, and performance improvements and was recognized as the Advisory
Firm of the Year 2010 by Energy Risk Magazine.
Structure assists companies in implementing their Smart Grid initiatives through comprehensive strategy
development, business case creation and refinement, vendor and system selection, program management,
process re-engineering, system implementation, legacy system integration, and testing of components and/or
end-to-end solutions.
The Structure workforce is comprised of diverse utility and energy professionals with extensive experience in
the energy industry, as well as regulatory program development with NERC, FERC, and other compliance
standards.
Structure specializes in key energy industry areas including Smart Grid/Distribution Operations/Distribution
Automation, SCADA & Energy Management Systems, Energy Trading & Risk Management, and Competitive
Energy Market Solutions.
Copyright 2010. Confidential and Proprietary
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Report is considered Final by
Structure Consulting Group, LLC.
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Commissioned by the
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Limitations
In connection with preparing this Report, Structure Consulting Group ("Structure") examined reproductions of
documents provided by Pacific Gas & Electric ("PG&E") and the California Public Utilities Commission
("CPUC"). Structure relied upon the completeness and accuracy of all documents and other information
requested by and provided to Structure, as well as such other records, agreements, test results, and
documents requested from the CPUC and PG&E and deemed necessary or relevant as the basis for our
Report. In such examinations, Structure assumed (i) the genuineness of all documents reviewed by Structure,
(ii) the conformity of the copies received by Structure to the original documents, and (iii) the authenticity of the
original documents. Structure further assumed that each of the parties to the documents and agreements
reviewed by Structure had the full power, authority, and legal right under its governing documents, corporate
legislation, and applicable laws and regulations to execute and perform its obligations under all documents
executed by it. Structure assumed that the documents reviewed by Structure were free from any fraud or
misrepresentation and the truth, as were the accuracy of representations and warranties in our interviews with
PG&E employees and other representatives. This Report was based solely upon the information received by
Structure from the CPUC, PG&E employees, PG&E Customers, PG&E vendors and representatives.
Structure assumed that the information received was accurate and complete information and documentation.
Subject to the foregoing, Structure has conducted an independent assessment of the matters that Structure
believes to be reasonably necessary to produce this Report. Structure was limited in scope and was not
requested nor performed an exhaustive review of all Smart Meter system deployment documentations,
configurations, and meter installations. Structure has used its reasonable efforts and impartial assessment to
ensure the independence and accuracy of the facts contained in this Report.
to Structure Consulting Group, LLC.
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Commissioned by the
California Public Utilties Commission
Executive Summary Table of Contents
Structure Consulting Group Overview....................................................................................................................................................................3
Limitations ..................................................................................................................................................................................................................4
Executive Summary ...................................................................................................................................................................................................6
A. Introduction ......................................................................................................................................................................................................6
B. Summary
of Key Findings ...............................................................................................................................................................................8
C. Work Scope....................................................................................................................................................................................................12
C.1 Laboratory Meter Testing .....................................................................................................................................................................13
C.2 Field Meter Testing ................................................................................................................................................................................ 14
C.3 End-to-End System Testing................................................................................................................................................................... 14
C.4 High Bill Complaint Analysis..................................................................................................................................................................15
C.5 Best Practices Associated with Smart Meters ...................................................................................................................................... 16
C.6 Security Assessment ............................................................................................................................................................................. 17
D. Detailed Summary of Observations and Findings .........................................................................................................................................18
D.1 Laboratory Meter Testing ......................................................................................................................................................................18
D.1.1 Laboratory Meter Testing Findings Summary .....................................................................................................................18
D.1.2 Laboratory Meter Testing Findings Details ......................................................................................................................... 18
D.2 Field Meter Testing ................................................................................................................................................................................ 19
D.2.1 Field Meter Testing Findings Summary...............................................................................................................................19
D.2.2 Field Meter Testing Findings Details ...................................................................................................................................21
D.3 End-to-End System Testing...................................................................................................................................................................24
D.3.1 End-to-End System Testing Findings Summary .................................................................................................................24
D.3.2 End-to-End System Testing Findings Details......................................................................................................................25
D.4 High Bill Complaint Analysis..................................................................................................................................................................26
D.4.2.1 Customer Complaint Process ........................................................................................................................................... 27
D.4.2.2 Customer Interviews ......................................................................................................................................................... 30
D.5 Best Practices Associated with Smart Meters ...................................................................................................................................... 32
D.6 Security Assessment ............................................................................................................................................................................. 34
D.7 Other Observations................................................................................................................................................................................34
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Commissioned by the
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Caliornia Public Utilites Commission
Executive Summary
A. Introduction
Pursuant to California Public Utilities Commission ("CPUC") decisions 0.06-07-027 and 0.09-03-026, Pacific
Gas and Electric ("PG&E") was given approval for full deployment of an Advanced Meter Infrastructure (AMI)
Project that included upgrading both metering and communications networks as well as the related
computerized systems and software for 5.1 million electric meters and 4.2 millon gas meters within the PG&E
territory. PG&E's AMI Project, subsequently named the SmartMeter™ Program, initiated meter deployment in
2007. During the first half of 2010, PG&E actively deployed Smart Meters at an average rate of 176,000 gas
and electric meters per month. As of June 2010, 3,146,000 electric and 3,101,000 gas Smart Meters had been
installed throughout PG&E's service territory.
By the fall of 2009, the CPUC had received over 600 Smart Meter consumer complaints about "unexpectedly
high" bils and allegations that the new electric Smart Meters were not accurately recording electric usage,
almost all of which were from PG&E's service area. The initial CPUC complaints were supplemented by
complaints provided by Senators Dean Florez (D-Shafter) and Roy Ashburn (R-Bakersfield), identified during
town hall meetings in Bakersfield and Fresno. In response to these complaints, the CPUC committed to
conduct an independent review to determine whether PG&E's Smart Meter system was correctly measuring
and billng electric usage.
On April 1, 2010, the CPUC contracted with Structure Consulting Group LLC ("Structure") to provide an
independent report related to testing and validating meter and billng accuracy of PG&E's residential electric
Smart Meters. The five month evaluation, labeled the PG&E Advanced Metering Assessment Report and
hereafter referred to as "The Assessment", culminated in the production of this report, issued on September 2,
2010.
The Assessment focused on addressing residential electric Customer concerns that Smart Meters caused
higher energy bils. The Assessment's scope and objective was to independently assess whether PG&E's
electric Smart Meter system and related billng system had been measuring and calculating electric usage
accurately, and billing PG&E Customers appropriately for their usage. The Assessment included meter
testing, end-to-end system testing, an evaluation of high bill complaints, and an evaluation of PG&E's Smart
Meter deployment as compared to industry best practices.
Structure segregated The Assessment's scope into the following areas:
Conducted
accurately at a functional
environmental conditions.
Field Meter Testing
Involved testing Customer meters at their premises to determine
Registration Accuracy within an established tolerance range. Customers
were selected to provide a representative cross-section of PG&E's
End-to-End System
Testing
a ulation base, as a licable to the field testin scenarios.
Comprised of a combination of laboratory and field tests, to determine
the effectiveness of PG&E SmartMeter and billing systems' efficacy to
ca ture meter data information.
Page 6 of 34 Report is considered Final by
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Performed on a subset of the Customers identified as part of the High
determine trends in high bills associated
Bill Complaint population to
with meter type, usage patterns, and billing issues. The Customer base
for this analysis was drawn from complaints received by the CPUC, town
hall meetings organized by state senators, and PG&E. Customer
interviews were conducted from the High Bill Complaint group to evalute
the circumstances related to the complaint, PG&E's handling of the
com laint, and an associated resolutions.
Best Practices
Associated with Smart
Meters
Security Assessment
Assessed across the energy industry to provide insight into Smart Meter
operations compared to PG&E's Smart Meter program.
Performed a review of PG&E's cyber security framework focused on
PG&E's Smart Meter system as part of the evaluation. The review was
limited and conducted with a focus on the smart grid system utilizing the
applicable sections of the "AMI System Security Requirements"
developed by the Smart Grid industry's OpenSG AMI-SEC Task Force.
The security assessment was performed to determine whether controls
were established and documented around industr -standard criteria.
Figure 1: Structure's PG&E AMI Assessment Scope
Structure performed an impartial and independent evaluation, employing reasonable efforts to complete the
engagement work agreed to by the CPUC within a reasonable timeframe, and with the understanding that
supporting documentation and information was provided by the CPUC and PG&E on a timely basis.
Throughout the duration of the Assessment, Structure did not share the results or findings of the Assessment
with PG&E, with the exception of results for a limited number of field meter tests that showed an out of
tolerance or unable to test condition. This limited disclosure to PG&E was done independently of this report to
allow PG&E the opportunity to promptly investigate the situation and take any mitigation measure at their
discretion to minimize the impact on the Customer. The findings from this study were developed
independently of the CPUC and PG&E with regards to previous or current litigation and or regulatory actions.
While this report may be utilized by the CPUC to determine future requirements related to Smart Meters and
the impact of Smart Meters on Customers, Structure's obligation associated with this evaluation should be
considered complete upon delivery of this report to the CPUC. Dissemination of the report and its contents will
be at the discretion of the CPUC in accordance with applicable State of California regulations.
This Executive Summary should not be taken stand alone from the entirety of the report, and should be
considered a culmination of information, facts, tests, explanations, and limitations described throughout the
entirety of the report.
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Commissioned by the
B. Summary of Key Findings
From April 1, 2010, to August 25, 2010, Structure reviewed relevant documentation related to PG&E's
SmartMeter™ equipment, systems, and processes and compared it to industry standards, independentlyperformed customer inteNiews, and PG&E-provided vendor specifications and internal documentation. This
evaluation principally consisted of an assessment of PG&E's accuracy and conformity to meter standards,
analytical procedures applied to customer data, business processes, and practices. Due to the number of
systems and process within the PG&E framework, this Assessment reflects Structure's opinion on only the
scope of work which Structure was requested to perform.
The CPUC tasked Structure with addressing three broad questions related to PG&E's SmartMeter™ system,
focusing on residential electric Customers. Working independently and with the facilitation of the CPUC,
Structure's Assessment yielded the following findings related to CPUC's inquiries involving PG&E's residential
electric SmartMeters™:
1. Does PG&E's SmartMeter™ system measure and bill electric usage accurately, both now and since
PG&E's Smart Meter deployment began?
PRESENT: While Structure cannot ensure that all issues related to the SmartMete?M program have
been identified or that future issues may not develop at a later date due to process, controls, or
technical modifications instituted after the completion of The Assessment, Structure's evaluation
provides the reasonable conclusion that PG&E's SmartMeters™ are accurately recording electric
usage within acceptable CPUC tolerances, and are being accurately utiized in Customer biling.
SINCE DEPLOYMENT: Although Structure was unable to test electromechanical and Smart Meters
since PG&E's program began, Structure reviewed PG&E's SmartMete?M program documentation
issue logs, incident reports, and analysis of historical customer complaints and did not identiy
systemic issues in the measuring and billng of electric usage within PG&E's SmartMete?M system for
the deployment period prior to our Assessment beyond those that had already been previously
reported to the CPUC. Identified exceptions related to meter and billng issues appeared to have been
limited and did not appear to have been prevalent in the overall deployed Smart Meter population.
2. What factors contributed to Smart Meter high bil complaints?
High bil Customer complaint analysis took the form of scrutinizing PG&E's internal meter data
processing activities, reviewing historical data provided by PG&E, and performing Customer interviews
related to high bil complaints. Structure's Assessment identified multiple factors that appeared to
contribute to the escalation of Smart Meter high bil complaints during late 2009 and early 2010,
including:
· Customer Usage:
o Meter deployment schedules coincided with increased energy usage caused by a heat
wave.
o Some Customers experienced load changes that were reflective of changes in personal
circumstances. Examples included room additions, pool additions, and equipment
malfunctions.
o Electromechanical meter degradation that was also identified as part of Structure's field
meter testing.
· Rates:
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o Rate increases compounded the financial impact of the additonal weather-related usage,
resulting in higher bíls that occurred as Smart Meters were being installed.
o Incorrectly applied rates that were based upon historical premise assumptions.
o Rate-based inquires that increased as Customer bíls escalated. Requests for new or
renewed financial assistance through California Alternate Rates for Energy (CARE) were
identified as potential reductions of financial impacts related to higher bils.
· Customer Service:
o PG&E processes did not address the Customer concerns associated with the new
equipment and usage changes.
o Customer skepticism regarding the new advanced meter technology was not effectively
addressed by PG&E on a timely basis.
o Customers interviewed during this assessment did not consider their complaint resolved,
despite indications from PG&E and CPUC that the Customer agreed with the resolution
o PG&E Customer complaint resolution did not provide of interval read information available
with Smart Meters, which may have assisted Customers' understanding of hourly usage
patterns.
· Process Issues:
o Customers indicated that communications/notifications surrounding physical meter
installation were lacking, or that the Customer had issues with the installation personnel.
o PG&E utiized field meter readers for an average of 131 days after Smart Meters were
installed, resultng in similar meter reading errors as electromechanical meters. The
transiton to automate the Smart Meter data for use in biling was not clearly addressed
with Customers.
o PG&E's system tolerances related to billng qualiy control were not stringent enough,
resultng in multple bíl cancelations and re-billngs, which were confusing to Customers.
3. How does PG&E's SmartMete/M Program's past and current operational and deployment compare
against the framework of industry best practices?
Structure found PG&E to have been historically in compliance, or have recently come into compliance,
with the majority of Best Practices Associated with Smart Meters. Structure identified several items of
partial or non-compliance related to industry best practices during The Assessment, which have been
recognized by PG&E through their presentations of information as shortcomings to be addressed:
a. The lack of documentation verifying compliance with the Meter Deployment best practice to
deploy WAN/LAN collectors prior to meter deployment.
i. By not deploying the communication backbone prior to meter deployment, the time to
transition meter reading from manual to Advanced Metering Infrastructure (AMI)
system readings is exacerbated, extending to an average of 131 days over the
implementation period. This allows a continuation of the higher error rate associated
with manual meter reading, and may contribute to the perception that the Smart
Meters are inaccurate.
b. The inabílty to verify compliance around:
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i. The Meter Data Managements (MDMS)lnterface best practice to correlate AMI meter
events and alarms with Validation, Estimating and Editing (VEE) and Customer
Information System (CIS) audits and checks for automated exception handling; and
ii. The VEE Best Practice of MOMS must provide an on-line method, with workflow,
resolving validation errors rather than reports.
These lapses have created a situation where data required manual editing, causing cancel
Ire-bils and
delayed processing of Customer data in a relatively small portion of the bils processed. The
cancel
Ire-bils and delayed processing potentially increased the days within a biling cycle presented in
Customer's bils, as reflected in a portion of the High Bil complaints, and furthered Customer
perception that Smart Meters may not have been accurate.
Based upon Structure's review of requested PG&E documentation and Structure's associated testing,
Structure determined that previously-identified issues brought to CPUC's attention were being appropriately
addressed by PG&E. Structure's testing did not uncover issues that would challenge that PG&E's Smart
Meters were accurately measuring and recording electric usage, or that PG&E's internal systems were
accurately utilizing this data for biling purposes. Structure identified no relevant correlation between installed
Smart Meters, impacts to billing on installed Smart Meters, and residential Customer Smart Meter high bill
complaints. Structure did identify certain events and circumstances, including sub-optimal Customer service
and variable implementations of industry best practices that contributed to the increase in Smart Meter high bill
complaints. The concerns uncovered should be addressed, but did not appear to be related to the ability of
PG&E's Smart Meter System to measure and bill electric usage correctly.
Overall, Structure found that the AMI technology deployed by PG&E appears to be 1)
consistent with industry standards, based upon the goals of the AMI implementation
and upgrades approved by the CPUC, and 2) accurate from a metering and billng
perspective. Structure identified gaps in Customer services and processes related to
high bil complaints, and determined certain PG&E practices to be partially noncompliant relative to industry best practices.
The following Figure provides a high-level summary of Structure's findings for each of the PG&E AMI
Assessment's areas of focus.
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All of the Smart Meters tested in Structure's independent laboratory
passed the accuracy testing. The Smart Meters subjected to
environmental stress testing in a controlled temperature chamber at
reference, high, and low temperatures all fell within the American
National Standards Institute ANSI standards.
. Structure's Pass/Fail Criteria was based upon the CPUC
Field Meter Testing
Standard of f2.0% for electromechanical meters and Smart
Meters.
. Of the 613 Smart Meter field tests, 611 meters were successfully
tested and 100% passed Average Registration Accuracy. One
meter was found to have serious errors and be malfunctioning on
arrival, and one was found to have serious event errors upon
installation; these meters were therefore excluded from testing.
· Of the 147 completed electromechanical meter field tests, 141
meters passed and 6 failed Average Registration Accuracy. One
meter was found to be non-functional, registering zero on all
tests, and was therefore excluded from testing.
End-to-End System Testing By utilizing a representative, small sample size to confirm meter-tobill system accuracy, Structure did not identify deviations during
testing that indicated a systemic problem in the meter biling
s stem's accurac .
High Bill Complaint Analysis After reviewing and analyzing over 1,378 High Bill complaints,
Structure did not identify pervasive issues with meter data or billing
systems. Results from 20 High Bill Complaint Customer interviews
identified service issues around complaint management by PG&E
and the CPUC.
Structure found PG&E to have been historically in compliance, or
have recently come into compliance, with the majority of industry
best practices associated with Smart Meters. Structure identified
several items of some concern during the Assessment, which have
been recognized by PG&E, through their presentation of information,
Best Practices Associated
with Smart Meters
as shortcomin s to be addressed.
Structure concluded that PG&E has developed a cyber security
framework that meets the objectives established in the Smart Grid
Security Assessment
industry's OpenSG AMI-SEC Task Force "AMI System Security
Re uirements" that were reviewed as art of this evaluation.
Figure 2: Structure's PG&E AMI Assessment Findings Summary
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C. Work Scope
Structure's evaluation focused primarily on evaluating meter accuracy and advanced metering system
capabilities to accurately determine and bill Customer electric usage for PG&E's residential electric Smart
Meter installations. Structure also evaluated PG&E's Smart Meter system deployment current and historical
business practices against industry best practices and standards and assessed PG&E's AMI security
framework. The Assessment also included addressing the influx of high bill complaints that were perceived by
Customers as being Smart Meter-related. Historical meter accuracy and associated meter replacement
firmware upgrades were not tested as part of the scope of this engagement, as Structure was not able to
evaluate the meters at the time that those complaints were initiated.
During project planning and initiation, PG&E provided a system overview that included previous meter testing
performed, meter reading and biling transition scheduling, and high bil complaints received. Based upon the
overview provided, Structure consulted with the CPUC to increase the meter accuracy testing and associated
Customer complaint analysis on PG&E's electric Customers as part of The Assessment. Structure worked
with the CPUC to modify the project scope to better evaluate PG&E's AMI systems based upon data
availability, budget constraints, and the available timeframe. Some scope modifications resulted from
additional efforts required to complete the proposed work, as discussed in the Scope of Work section of this
report.
During the course of The Assessment that spanned April to August of 2010, Structure independently tested
over 750 Smart Meters and 147 electromechanical meters. Structure also reviewed the 1,378 electric Smart
Meter Customer accounts from a PG&E provided list of 2,915 Smart Meter electric and gas high bill-based
complaints. Structure requested that PG&E provide a detailed explanation of 73 accounts where Structure
identified biling data anomalies that could not be attributed to the Customer's usage profile. Structure also
attempted to contact over 100 of the high-bil complaint Customers, resulting in 20 high-bil complaint phone
interviews. Structure reviewed the accounts of each of the interviews with PG&E's complaint resolution team
for further analysis.
Throughout the evaluation, less than a 1,000 pages of double sided hard-copy sheets were transmitted in
consideration of California's green initiatives. Approximately 6GB of zipped compressed data in the form of
1,600 documents was provided by PG&E, which contained approximately 27,000 pages or slides and 2,000
worksheets. Structure electronically pulled 2.4 millon sample Customer stratifications from over 5.2 milion
Customer meter locations.
During the course of the project, Structure reviewed manufacturer specifications, procedures, and relevant
data associated with meter manufacturers, communication network, and meter data management and billing
systems. Structure also held interviews with PG&E vendors and performed site visits to PG&E and vendor
facilities to observe processes and procedures. Detailed methodology, procedures, test results, and identified
issues can be found in the appropriate sections of this Assessment.
Structure's work included meetings and interviews with PG&E resources and subject matter experts and
Customers to obtain insight and information relevant to our evaluation. Structure also maintained a call center
associated with the field meter testing that allowed Customers to address questions associated with the
evaluation meter testing. In addition, a meeting was held with the TURN consumer advocacy group at their
request. As part of the assessment, Structure reviewed documents and held over numerous interviews with
PG&E personnel, focused on process and methodology. Additional time was spent with PG&E security
personnel to conduct the security assessment.
The number of meter tests and customer interviews performed was based upon cost/benefit analysis
conducted by Structure in conjunction with the CPUC at various points throughout the project. The sample
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sizes selected were determined to provide a reasonable representation of the PG&E meter and high bil
complaint populations based upon the CPUC-requested scope of work.
The project scope was divided into the following areas:
·
·
·
·
·
Laboratory Meter Testing
Field Meter Testing
End-to-End System Testing
High Bil Complaint Analysis
Best Practices Associated with Smart Meters
· Security Assessment
From the initial RFP response throughout the project, Structure contracted for the services of Trimark
Associates ("Trimark"). Trimark's credentials included certification as a Meter Service Provider (MSP) in
California by the CPUC. Trimark has provided metering and meter data management services for over nine
years within California and throughout North America. The synergy between the two companies allowed
Structure to utilize Trimark as a dedicated contractor to perform the meter-based field and laboratory testing
defined throughout this report. As the sole contractor to Structure for this Assessment, further reference to
Trimark work within this report may be included under the Structure reference.
The following sections provide scope overviews associated with each of the key project areas.
C.1 Laboratory Meter Testing
Laboratory meter testing was performed in a qualified, non-PG&E laboratory located within the PG&E territory
and overseen by Structure resources. Structure verified meter accuracy and factory programming laboratory
tests on a representative meter sample set obtained from PG&E's warehouse facilities. Structure allocated a
portion of the sample set meters for end-to-end and environmental testing, and the remainder for installation at
residential Customer premises.
Structure utilized a subset of the PG&E warehouse randomly selected meters to perform environmental testing
in the laboratory, where the meters were subjected to temperature-based stress tests. An additional set of
meters were used for end-to-end system testing to monitor meter activity from installation through billing. The
tests are highlighted in the following Figure, Summary of Structure's Test Scenarios, Scenarios 1 and 2.
Laborator
Laborator
Field
Field
Field
Field
Field
Field
Scenario 1
Scenario 2
Scenario 3
Scenario 4
Scenario 5
Scenario 6
Scenario 7
2010. Confidential and Proprietary
Copyright
..
~
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The laboratory and field test scenarios were developed as a representative set of tests normally used by utility
companies to determine compliance to Public Utility Commission accuracy standards based on ANSI Standard
C12.20.
C.2 Field Meter Testing
The Assessment's field meter testing utilized the Standards for Meter Installation, Maintenance, Testing and
Calibration as set forth in the Direct Access Standards for Metering and Meter Data (DASMMD) and American
National Standards Institute (ANSI) standards to verify the accuracy associated with PG&E's Smart Meters.
Structure also performed field testing on a sample of electromechanical meters installed at electric residential
Customer locations in order to confirm meter accuracy. The guidelines for testing were based on DASMMD
standards that were established in 1998, which provided for electromechanical meters and did not include
updates applicable to Smart Meter systems. Meter accuracy was monitored based upon the DASMMD
requirements. Based upon discussion with CPUC, the DASMMD standards were the established regulatory
guidelines to be followed. The PG&E and manufacturer comparisons were utilized for reference purposes
only.
Field meter testing was conducted using six scenarios that were identified by Structure to test both the
electromechanical and Smart Meters in the field and evaluate both the accuracy of Customers'
electromechanical and Smart Meters and the associated procedures. The conducted tests are summarized in
Figure 3, Scenario 3 through Scenario 8. Customers whose meters were selected for testing were contacted
by mail and/or by a Structure representative to describe the process and test coordination.
Each of the field testing scenarios was conducted by Structure and accompanied by PG&E's meter
technicians, and followed industry-standard established procedures as described in this report and associated
documentation. All meter testing was performed by Structure technicians for Scenarios 3-7; in Scenario 8,
Structure observed PG&E's field processes for shadow meter tests. The field meter testing included:
· Site verification
· Meter type and form factor verification
· Proper installation
· Meter program and accuracy verification
Field-based testing focused on residential meters; thus, testing of commercial meters was excluded from the
scope and the test scenarios.
C.3 End-to-End System Testing
End-to-End System Testing included both laboratory and field testing.
End-to-End laboratory testing was performed on five PG&E Smart meters, with five Elster™ digital meters
used as "shadow" meters. Each of these meter pairs were subjected to a different amount of load, reflecting
measurement at various rate tiers over the test period. In addition, the end-to-end "shadow" meters were also
subjected to common exceptions to normal conditions, including power outages, voltage swells, voltage sags,
and loss of Radio Frequency reception. Inclusion of common exceptions facilitated testing PG&E's capability
to perform validation, editing, and estimation (VEE) processes in compliance with CPUC rules, and without
introducing errors into Customer bills.
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"Proxy" Customer accounts were created within PG&E's billing system for each of the end-to-end meters,
giving Structure the ability to determine PG&E's application of billing determinants and rate assignments, as
well as the accuracy and the timeliness of physical bil issuance to residential electric Customers. The end-toend test process was designed for completion over the course of one PG&E biling cycle.
End-to-End field testing utilized the field testing shadow meter installations for selected High Bill Complaint
Customers as part of field meter testing Scenario 6. The field testing shadow meter setup used the existing
installed PG&E Smart Meter and an Elster digital shadow meter installed side-by-side to measure the
Customer's usage simultaneously through both meters. Structure also utilized these same installations to
verify the flow of meter usage and event data from the Customer premise, through the AMI and Billng
systems, to the Customer's receipt of the printed bilL.
A PG&E-provided representation of PG&E's metering and billng system connectivity is found in the Figure
below. The information tested in end-to-end system testing was processed through these systems.
¡ Bmií'~g
e
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t
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M...._
.-ncl'
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e
~
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En:/ / M....iit.
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I" Sf....
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Figure 4: PG&E.Provided Representation of PG&E's Metering/Biling Systems Connectivity
C.4 High Bill Complaint Analysis
To perform the High Bil Complaint Analysis, Structure examined the entire population of 1,378 Smart Meter
electric high bil complaints consisting of those offcially filed with the CPUC, those provided by the offce of
Senate Majority Leader Dean Florez (D-Shafter), and Smart Meter High Bill Complaints specifically identified
:,~'12
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and provided by PG&E for the period September 17, 2007 to April 30, 2010. Structure further refined the High
Bill complaint list to focus on determining the underlying nature of the complaint by utilizing account information
and reviewing detailed historical usage for 1,066 of the Customer complaint accounts with available historical
usage data specifically related to residential electric Smart Meters. The detailed analysis of 1,066 accounts
was done by evaluating the High Bill Complaint Customers' usage patterns and account specific information
prior to and after Smart Meter installation to identify impacts of weather, extended bill cycles, cancel/re-bills,
estimated meter reads, and usage spikes on Customer complaints.
A targeted selection of 73 Customer complaints was chosen based on account activity that suggested the
potential for identifying underlying system or process issues, and was further analyzed to identify contributing
factors for the complaints. The analysis on the 73 complaints included a detailed review of complaint
resolution documentation, usage analysis, complaint history, account history, and Customer Service and
Customer interaction notes. Structure utilized the 73 complaints reviewed and an additional 27 complaints with
similar profiles to contact Customers for potential interviews. Of the 100 potential Customer interview
participants, 20 agreed to participate in one-on-one interviews focused on documenting Customer rationale
when initiating the complaint process, the Customer's experiences, premise conditions, energy usage, and the
Customer's insight into the subsequent PG&E resolution process. Structure followed the 20 Customer
interviews with an examination of each of their accounts with the PG&E Escalated Complaints team, to better
understand the PG&E processes followed and the PG&E outcome of the Customer complaint.
Structure also specifically reviewed Customer usage and resolution status associated with 231 of 300
Bakersfield and Fresno electric Smart Meter town hall complaints, including the underlying analysis performed
by PG&E and the associated resolution process for these accounts.
C.5 Best Practices Associated with Smart Meters
To evaluate Best Practices, Structure reviewed PG&E's documentation of past and current operational and
deployment policies, processes, and procedures against a framework of industry best practices. The
framework was developed by Structure subject matter experts with combined electric and gas field, operations,
and biling experience of over 75 years, and presented to three independent Smart Meter industry experts for
review and input. Structure compiled the contributions of these experts, applied it to the framework, and
compared PG&E's policies, processes, and procedures against the established framework.
The Best Practices work included review of eight key areas associated with Smart Meters:
· Meter manufacturing quality control
· Meter installation standards
· Meter equipment safety
· Meter deployment
· Meter Data Management interfaces
. Validating, Estimating and Editing for monthly and interval data
· Account biling
. High bill complaint troubleshooting
The Best Practice analysis also identified business process improvements initiated by PG&E since January
2010 to enhance meter accuracy and increase customer satisfaction. Inclusion of the improvements was
intended to document PG&E's efforts to align with industry Best Practices associated with Smart Meters.
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Best Practices included in this report are reflective of the current industry environment for the areas addressed,
as provided by Structure and industry experts retained by Structure. The views and opinions expressed in The
Assessment may not reflect the views or opinions of all industry experts, and may change as Smart Meter
systems continue to mature.
C.6 Security Assessment
Structure performed a review of PG&E's cyber security framework focused on the smart grid system as part of
The Assessment. The review was limited based on priority, time, and budget, and was conducted with a focus
on the smart grid system, utilizing the applicable sections of the "AMI System Security Requirements"
developed by the Smart Grid industry's OpenSG AMI-SEC Task Force. The security assessment was
performed to provide a confirmation that controls were established and documented around:
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
Corporate Cyber Security Approach
Confidentiality and Privacy
Data and System Integrity
System Availability
Identification and Authentication of Users
Authorization of Users
Accounting and Non-Repudiation
Anomaly Detection Services
Boundary Services and Interfaces
Cryptographic Services
Resource Management Services
Development Rigor
Organization Rigor
Handling and Operating Rigor
Accou ntabi I ity
Per The Assessment's scope, Structure utilized several methods to perform the review, including interviews
and documentation reviews of PG&E policies and procedures, referred to as a "paper" review of PG&E's
security framework. The review included interviews with key PG&E personnel tasked with managing security,
inspection of relevant PG&E documents, and review of third-party audit reports where applicable and available.
The information obtained through these methods was then compared against the applicable sections of the
"AMI System Security Requirements" standards developed by the Smart Grid industry's OpenSG AMI-SEC
Task Force. A comparison to cyber security "best practices" was also performed.
An in-depth qualitative assessment of PG&E's framework implementation was beyond the scope of this
Assessment. An evaluation of this nature would have taken several months to evaluate each major subsystem within the Smart Grid system, as well as additional time to evaluate the implementation within PG&E's
security framework. An in-depth review would involve reviewing firewall rules, system configurations, user
permissions, training, background checks, etc.
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D. Detailed Summary of Observations and Findings
The following summary of Structure's findings reflects the results of The Assessment's testing and analysis.
Structure found the summarized results to be representative of the overall PG&E AMI program; however, due
to the accelerated nature of the engagement, Structure's Assessment was limited its ability to express an
opinion on all of the AMI processes and procedures used at PG&E. Accordingly, the results should be taken in
the context of the data reviewed.
D.1 Laboratory Meter Testing
D.1.1 Laboratory Meter Testing Findings Summary
Structure utilized a laboratory testing facility that was independent from PG&E to conduct tests for meter
accuracy, environmental stresses, and end-to-end system functionality. Structure selected 174 Smart Meters
from PG&E's warehouses using a randomized selection process based on representative vendor and meter
type criteria, and then tested the meters for accuracy in the independent laboratory. All of the tested Smart
Meters passed the accuracy testing. Structure then utilized a portion of the selected Smart Meters for
environmental stress testing, and found all of the meters to fall within the American National Standards
Institute (ANSI) standards when tested in a controlled temperature chamber at reference, high, and low
temperatures.
D.1.2 Laboratory Meter Testing Findings Details
Structure set aside 18 of the 174 meters selected from the warehouses as "spares", and conducted laboratory-
based accuracy tests on the remaining 156 stock PG&E Smart Meters selected from the five randomly
selected PG&E warehouses. The sample set consisted of a range of meter types and meter manufacturers
representing a representative sample of meters available in the PG&E in-stock inventory, which were procured
using a random meter selection methodology.
The Results of the Laboratory Accuracy Tests were:
. 100% of the 156 PG&E stock Smart Meters tested were within an accuracy range of 99.81 % to
100.15%, with an average accuracy of 100.01 % and a standard deviation of 0.0408%.
. The meters passed the :to.2% acceptable accuracy standard established by the meter manufacturer,
which also satisfied the CPUC accuracy requirement of :t2.0%.
load, light load, and with a 50% power factor
Following an initial test to verify the accuracy of the meters at full
in accordance with ANSI standards, a subset of these meters were used in Structure's laboratory and field test
scenarios.
Environmental testing consisted of subjecting six of the PG&E Smart Meters to extreme hot and cold
conditions in a controlled environmental chamber designed to accurately replicate these conditions in
accordance with ANSI C12.20 specifications. The meters were placed into the environmental chamber for 24
hours and allowed to reach "equilibrium". The temperature was then adjusted, and the test performed.
The summary findings from the Environmental Laboratory Meter Tests were:
. When subjected to +50 degrees Celsius (+122 degrees Fahrenheit) for 24 hours, all of the meters
tested within the :t2% CPUC standard; however, one out of the six meters did not conform to the ANSI
C12.20 maximum deviation of :to.5% from reference test temperature standard used by the meter
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manufacturer. The non-conforming meter exceeded the allowed 0.5% deviation by 0.07% during the
full load test. The non-conforming meter's deviation was slightly out of tolerance on the Full Load and
Light Load test, but the meter passed the CPUC standard for accuracy when adjusted for Average
Meter Registration Accuracy (Full Load Test + Light Load Test)/2.
· When subjected to -20 degrees Celsius (-4 degrees Fahrenheit) for 24 hours, all of the meters tested
within the PG&E and CPUC criteria of :10.5% and :12%, respectively. All of the meters passed the
ANSI C12.20 maximum deviation of :10.5% from the reference test temperature standard used by the
meter manufacturer.
0.2 Field Meter Testing
0.2.1 Field Meter Testing Findings Summary
Structure conducted field tests on 797 meters using defined procedures and protocols for each of the following
six scenarios:
· Scenario 3: Electromechanical Meter Test and Smart Meter Field Replacement
· Scenario 4: Non-High Bill Complaint Smart Meter Field Test
· Scenario 5: High Bill Complaint Smart Meter Field Test
· Scenario 6: High Bill Complaint Shadow Meter Field Test
· Scenario 7: Non-High Bill Complaint Electromechanical Meter Field Test
. Scenario 8: High Bill Complaint PG&E-Installed Shadow Meter Test Verification
load, light load, and with an applied power factor.
Structure's field tests measured accuracy of the meters at full
The results were tracked to acceptance levels for the CPUC (:12% for both Smart Meters and
electromechanical meters), PG&E (:10.5% for Smart Meters, :12% for electromechanical meters), and the
manufacturer (:10.2% for Smart Meters, :12% for electromechanical meters). Structure's Pass/Fail criterion
used in this report was based upon the CPUC standard of :12.0% for electromechanical meters and Smart
Meters.
Structure attempted 897 field meter tests and completed 797 field meter tests, including both Smart Meters
and electromechanical meters. Structure was unable to complete the remaining 100 meters due to normal
reasons, such as meter banks on apartment buildings preventing the installation of the dual socket required for
testing and meters locations that required extension ladders for access. Overall, a statistically valid,
randomized sample of Smart Meters representing the entire installed base of Smart Meters in the P&GE
territory was found to pass accuracy reading. Using the CPUC pass/fail criterion of :12.0%, 611 of the 613
Smart Meter field tests were completed, with 100% passing CPUC registration accuracy readings. Two Smart
Meters were found to have serious errors and be malfunctioning. One meter was found to have serious errors
and be malfunctioning on arrival, and one was found to have serious event errors upon installation; these
meters were therefore excluded from testing. The Average Registration Accuracy of the 611 meters tested
was 100.067%, with a Standard Deviation of 0.271%. Of the 147 completed electromechanical meter field
tests, 141 meters, or 95.92%, passed and 6, or 4.08%, failed accuracy readings.
Structure identified one meter that was registering a zero read during the field meter testing. After further
examination of PG&E's issue logs, the error was identified as a "data storage" issue. These data storage
issues had been identified by PG&E in 12,735 meters as of May 2010, potentially resulting in a subset of
Customers receiving zero usage or lower estimated bills. Data storage issues are one type of exception
disclosed by PG&E, and may include:
· Negative intervals
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· Large intervals
· Zero table
· Negative register readings
· Table resets
Str.ucture noted that these data storage issues were identified in early October 2009, with replacements
starting in May 2010. These errors were disclosed to the public and to the CPUC in May 2010. PG&E
subsequently initiated processes to address these issues in a timely and effective manner. As of July 2010,
the outstanding data storage issues had been reduced to 1,526 meters.
The following Figure illustrates the number of meters that passed and failed the accuracy test for all of the
Structure Field Meter Testing Scenarios, delineated by electromechanical meter tests in blue, and Smart Meter
tests in yellow. The field testing scenarios were referred to as "High Bill Complaint" and "Non-High Bil
Complaint" populations. The High Bil Complaint population was derived from complaints received directly by
the CPUC or PG&E and those received at the town hall meetings organized by state senators. Non-High Bill
Complaint refers to Customers who had not filed a high bill complaint through one of these channels.
. ....
Figure 5: Structure's Field Meter Testing Pass/Fail Accuracy Results by Field Test Scenario
N/A-S: Not Applicable-Shadow Meter
Of the 613 completed Smart Meter field tests, 611 meters were successfully tested and 100% passed Average
Registration Accuracy. One meter was found to have serious errors and be malfunctioning on arrival, and one
was found to have serious event errors upon installation; these meters were therefore excluded from testing.
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0.2.2 Field Meter Testing Findings Details
A description of Structure's field testing scenarios and summary of the scenario-based testing results are
presented in the following Figure. The field testing scenarios were referred to as "High Bill Complaint" and
"Non-High Bill Complaint" populations. The High Bill Complaint population was derived from complaints
received directly by the CPUC or PG&E and those received at the town hall meetings organized by state
senators. Non-High Bill Complaint refers to Customers who had not filed a high bil complaint through one of
these channels. Average registration accuracy is calculated using the equation (Light Load Test + Full Load
Test)/2 and refers to the average accuracy of a "register," which maintains a measure of the total power
consumption that passed through the meter over time.
Each of the following scenarios was performed independently of each other, and involved a unique Customer
premise.
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Electromechanical Meter Test
& Smart Meter Field
Replacement
Commissioned by the
Structure used a representative
sample of 50 Customers that
were scheduled to have their
electromechanical meter replaced
. One Smart Meter was found to have a
serious event error and be malfunctioning
upon installation, and was therefore excluded
from testing.
by PG&E. The electromechanical
meters were removed and
. 100% of the 44 tested Smart Meters used for
accuracy tested in the field at full
load, light load, and 50% power
factor. A laboratory-tested Smart
Meter was then accuracy-tested
in the field before being installed
in the Customer's premise. The
results of each of these tests were
recorded by the Structure
. Field test results of 44 of the previously
contractor. 47 successful
this scenario passed CPUC's accuracy
testing acceptance standard of :\2.0% in the
field test.
laboratory-tested Smart Meters indicated an
Average Registration Accuracy of 100.27%
during the field tests with a standard deviation
of 0.112%.
electromechanical meter tests
and 44 successful Smart Meter
tests were conducted for this
Scenario. The difference in
number of electromechanical
tests and Smart Meter tests was
due to 6 electromechanical
meters that failed. These meters
subsequently did not receive a
Smart Meter installation at the
time of the test; therefore,
Structure did not conduct a Smart
Meter test at that premise.
. One electromechanical meter was not
found to be functional, registering zero on
all tests; and was therefore excluded from
testing.
. 41 of 47 tested electromechanical meters
passed the CPUC's accuracy testing
standard of :\2.0% in the field test.
. Six of the 47 tested electromechanical meters
failed the CPUC Accuracy Standard of
:\2.0%, with one failing the Full Load and
Power Factor tests, one failing the Light Load
test, one failing the Power Factor test, and
three meters failing the Light Load and Power
Factor standard tests.
. Two of the six electromechanical meter
failures failed the Average Registration
Accuracy standard. All field-tested
electromechanical meters that were replaced
with Smart Meters were returned to PG&E
with an indication of whether or not they
passed the field test.
. The 47 tested electromechanical meters had
an Average Registration Accuracy of
99.556%, with a Standard Deviation of
1.343% for the successful tests.
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A representative sample of 532
Smart Meters was chosen from
the population of PG&E
Customers where a Smart Meter
had previously been installed by
PG&E and the Customers were
not in the High Bill Complaint list.
These meters were removed from
the Customer's meter socket and
placed in a calibrated field test set
on-site at the Customer's
premise, where the meters were
then accuracy-tested at full load,
light load and a 50% power factor.
In addition, the existing internal
meter program was verified to
. One Smart Meter (of the 532) was found to
have a serious event error and was
malfunctioning, and was thus excluded from
testing. The communication module on this
device was functional and had been reporting
zero usage for almost six months.
. 100% of the 531 tested meters tested within
the CPUC accuracy standard of
:t2.0%.Average Registration Accuracy ranged
from 98.345 % to 100.78% with an average of
100.075% and a standard deviation of
0.275%.
confirm ro er functionalit .
Scenario 5
High Bill Complaint Smart
Meter Field Test
Structure selected 50 Smart
Meter installations from the High
Bill Complaint population to verify
that the meter was properly
installed and to field test the
registration accuracy of the
. All 36 Smart Meters tested passed the CPUC
acceptance standard of :t2.0%.
. The Average Registration Accuracy for the
Scenario 5 meters was 100.004%, with a
Standard Deviation of 0.351%.
installed Smart Meter. 36 Smart
Meter tests were conducted for
this Scenario. At each location,
the Smar Meter was removed
and installed in a calibrated field
test set, where the meter was
accuracy tested at full load, light
load and a 50% power factor. In
addition, the existing internal
meter program was verified as
functionin ro erl .
Scenario 6
High Bill Complaint Shadow
Meter Field Test
Structure selected 20 locations
. The results of the 19 shadow meter tests
from the High Bill Complaint
population to install a Field
consisted of the existing installed
PG&E Smart Meter and an Elster
showed that the shadow meter reads were in
concert with the Smart Meter reads.
. The bills from both the lab-tested shadow
meters and the field-tested shadow meters
matched the expected results from manual
bill calculations.
digital Shadow meter installed
. Structure encountered four unauthorized
Shadow Meter setup, and
completed tests at 19 locations.
The Field Shadow meter setup
side-by-side to measure the
Customer's usage simultaneously
through both meters. These
meters were used to establish the
accuracy of the Customer meters
already installed by performing a
weekly accuracy check and
comparing the readings from the
two meters. In addition to verifying
Smart Meter accuracy, these
installations were also used to
PG&E meter swaps/meter tests during the
execution of this scenario, as noted in the
"Unauthorized PG&E Meter Swaps" section
of this report, and in Appendix F:
Unauthorized Scenario 6 Meter Swaps
Exhibitions. These meters were
subsequently not tested by Structure in the
field, but were retrieved from PG&E and
evaluated in the laboratory with no noted
verify the end-to-end accuracy
issues. Structure selected additional
thru the PG&E AMI system to the
accounts to test in lieu of the meters excluded
from test sample due to the unauthorized
customer bilL.
meter swap.
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Non-High Bill Complaint
Electromechanical Meter
Field Test
Structure used a representative
sample of 100 installed PG&E
electromechanical meters to verify
the accuracy of these meters in
the field. The meters were
removed from the customer
installation and placed in a
calibrated field test set to verify
their accuracy at full load, light
load, and at a 50% power factor.
Scenario 8
High Bill Complaint PG&E
Installed Shadow Meter Test
Verification
Structure accompanied PG&E
Meter personnel during the
installation of 18 shadow meter
tests performed by PG&E. These
installations consisted of the
installation of a side-by-side
electromechanical meter and
Smart Meter at the site of
Structure-selected High Bill
Complaint Customer's premises.
Structure reviewed PG&E's
installation practices to determine
if they were in line with
documented installation, testing
and meter reading procedures
and to determine if PG&E
followed their documented
. Scenario 7's test included 100 installed
PG&E electromechanical meters, with no
failures on the CPUC Standard of :t 2.0%.
. The 100 meters had an Average Meter
Registration Accuracy of 99.798% with a
Standard Deviation of 0.528%.
. The minimum Registration across all tests
(Full Load, Power Factor, and Light Load)
was 98.1%, and the maximum registration
across all tests was 101.95%.
. Of the 27 meters selected for Scenario 8, 18
were successfully completed with no
identified deviations, and nine were unable to
be completed due to premise restrictions and
meter installation routing schedules.
. In all test cases, PG&E complied with
internally documented practices and
procedures for the shadow test verification.
ractices and rocedures.
Figure
6: Structure's Field Meter Testing Summary of Results
D.3 End-to-End System Testing
D.3.1 End-to-End System Testing Findings Summary
End-to-end system testing was used to verify the accuracy of the PG&E Smart Meters, data communications
and associated systems, estimation routines, and the customer biling system, including bill printing. A
laboratory end-to-end test scenario was used to simulate system exception handling in a controlled
environment, including the addition of a meter access point that served as the collection point for the meter
information that was sent back to PG&E.
End-to-End laboratory testing was performed on five PG&E Smart Meters, with five Elster digital meters used
as parallel, side-by-side measurement, referred to in this Assessment as "shadow" meters. These end-to-end
laboratory tests involved creating a proxy Customer account, installng a Smart Meter for this account and an
electronic meter side-by-side to shadow the account's usage, and conducting tests from the time of installation
through to receiving a bilL. Structure established shadow meter test boards and conditions in the independent
laboratory for use in the end-to-end system testing, to determine whether the Smart Meters were accurately
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measuring energy consumption as compared to an independent electronic Meter. A field end-to-end test
scenario, Scenario 6, was used to test the actual performance at Customer-installed facilties.
Structure did not identify issues during the testing of the meter billing system accuracy. Structure encountered
an issue with PG&E's set-up of the proxy accounts, wherein Structure specified a specific billing address and
PG&E sent all of the proxy account bills to the wrong address. PG&E indicated that this occurred because
they did not follow their standard practices.
0.3.2 End-to-End System Testing Findings Details
Twenty-six Elster digital meters procured from the Elster meter manufacturer were laboratory-tested for
accuracy and utiized as an auxiliary/additional meter to record energy consumption on the secondary meters,
hereby referred to as a "shadow" meters in both the laboratory end-to-end testing and the field end-to-end
testing scenarios.
End-to-end laboratory testing was performed on five PG&E Smart Meters, with five Elster digital meters used
as shadow meters. Each of these meter pairs was subjected to a different amount of load, reflecting
measurement at various rate tiers over the test period. In addition, the meters were also subjected to common
exceptions to normal conditions often found in the field, including power outages, voltage swells, voltage sags,
and loss of Radio Frequency reception. Inclusion of the common exceptions facilitated testing PG&E's
capability to perform validation, editing, and estimation (VEE) processes in compliance with CPUC rules, and
without introducing errors into Customer bils. The referenced VEE standard was California Interval Data VEE
Rules Revision 2.0.
"Proxy" Structure Customer accounts were created within PG&E's billing system for each of the laboratorybased end-to-end meters, giving Structure the ability to determine PG&E's application of billng determinants
and rate assignments accuracy and the timeliness of physical bil issuance to residential electric Customers.
The end-to-end test process was designed for completion over the course of one PG&E biling cycle.
Structure encountered an issue with PG&E's set-up of the proxy accounts, wherein Structure specified a
specific biling address to be used instead of the premise address and PG&E sent all of the proxy account bills
to the wrong address. Structure specifically requested use of the billng address instead of the premise
address in order to accommodate a specific route and satisfy the specified bill cycle. The proxy bils were sent
to the "premise address" that was created for the proxy accounts, which was a fictitious address created by
PG&E for internal use for a premise that does not exist. Structure contacted PG&E when the bills were not
received, and subsequently received the bils. PG&E indicated that the bills were sent to the incorrect address
because they did not follow their standard practices for account setup. PG&E failed to note on the account that
bills were to be sent to the billng address, instead of the premise address, and told Structure that the billng
system defaulted to the premise address for bill delivery.
End-to-end field testing utilized four Scenario 6 field test shadow meter installations on selected High Bill
Complaint Customers. The field test shadow meter setup used the existing installed PG&E Smart Meter and
an Elster electronic shadow meter installed side-by-side to measure the Customer's usage simultaneously
through both meters. The meter comparison results are discussed in the Field Meter Testing section.
Structure also utilized these installations to verify the flow of meter usage and event data from the Customer
premise, through the PG&E AMI and Billing systems, to the Customer's receipt of the printed bilL.
Structure experienced initial laboratory testing setup challenges that were resolved within the first days of
testing. The challenges identified during setup did not impact the overall scope or development of testing
conclusions. The results of the end-to-end tests included:
10
12
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· End-to-End laboratory system testing verified that the representative sample of five Smart Meters
being billed through the PG&E systems had average accuracies compared to the reference Elster
meters of 0.06% with a standard deviation of 0.001 %. Meter Data Management System (MOMS)
validation routines were verified to be working accurately under the tested conditions, and billing
matched the expected results.
· Meter readings were verified as accurate between the Advanced Metering Infrastructure (AMI)
head-end, the Meter Data Management System (MOMS), and the Customer Care and Billing
(CC&B) systems.
· Application of biling determinants were verified as accurate, including the assignment of baseline
allocations, transition of billng through seasons, and transition of biling through new tariffs.
0.4 High Bill Complaint Analysis
0.4.1 High Bill Complaint Analysis Findings Summary
Structure obtained the complaint register associated with the electric Smart Meter High Bil Complaints from
both PG&E and the CPUC since the implementation of Smart Meters through June 10, 2010, for inclusion in
our analysis which included usage history for 1,378 records. A detailed analysis was performed on 1,066 of
these records. The records were analyzed for usage sensitivity to weather, unusual spikes, meter problems,
manual or system based issues, meter reading issues, rate impacts, and service issues. Structure further
analyzed a targeted sample of 73 complaints that were identified as having multiple issues and would likely
provide the greatest insight into potential PG&E system or process issues. Structure contacted 100 High Bill
Complaint including the 73 researched complaints, and conducted interviews with 20 Customers that had filed
complaints during the period and exhibited excessively high bill periods, cancel/re-bills, or complaint resolution
codes that reflected a potential problem. The 73 complaint accounts were also included in the field meter
tests.
As a result of the high bill complaint analysis, Structure did not identify problems with the Smart Meter data
utilized for billing. Structure identified the following factors that contributed to high bill complaints during late
2009 and early 2010:
· Customer Usage:
a Meter deployment schedules coincided with increased energy usage caused by a heat
wave.
a Some Customers experienced load changes that were reflective of changes in personal
circumstances. Examples included room additions, pool additions, and equipment
malfunctions.
a Electromechanical meter degradation that was also identified as part of Structure's field
meter testing.
· Rates:
a Rate increases compounded the financial impact of the additional weather-related usage,
resulting in higher bils that occurred as Smart Meters were being installed.
a Incorrectly applied rates that were based upon historical premise assumptions.
o Rate-based inquires that increased as Customer bills escalated. Requests for new or
renewed financial assistance through California Alternate Rates for Energy (CARE) were
identified as potential reductions of financial impacts related to higher bils.
· Customer Service:
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o PG&E processes did not address the Customer concerns associated with the new
equipment and usage changes.
o Customer skepticism regarding the new advanced meter technology was not effectively
addressed by PG&E on a timely basis.
o Customers interviewed during this assessment did not consider their complaint resolved,
despite indications from PG&E and CPUC that the Customer agreed with the resolution
o PG&E Customer complaint resolution did not provide of interval read information available
with Smart Meters, which may have assisted Customers' understanding of hourly usage
patterns.
· Process Issues:
o Customers indicated that communications/notifications surrounding physical meter
installation were lacking, or that the Customer had issues with the installation personnel.
o PG&E utilized field meter readers for an average of 131 days after Smart Meters were
installed, resulting in similar meter reading errors as electromechanical meters. The
transition to automate the Smart Meter data for use in billng was not clearly addressed
with Customers.
o PG&E's system tolerances related to biling quality control were not stringent enough,
resulting in multiple bil cancelations and re-bilings, which were confusing to Customers.
Additionally, Structure determined that the PG&E complaint resolution process was ineffcient and ineffective in
providing Customers with resolution details and education related to Smart Meters. Recent process changes
adopted by PG&E created Customer Relations resources that were focused on Smart Meters, along with a
group focused on resolving escalated complaints. Structure performed a complaint walkthrough with both the
PG&E groups and was satisfied that additional focus was being placed on resolving Customer complaints.
0.4.2 High Bill Complaint Analysis Findings Details
0.4.2.1 Customer Complaint Process
The Customer complaint process followed multiple paths, including contacting the CPUC Consumer Affairs
Branch (CAB) to file a complaint and filing directly with PG&E's Customer Relations Department. In some
cases, Customers registered complaints with both the CPUC and PG&E. Typically, Customers had filed more
than one complaint with PG&E. Included in the CPUC complaint list were complaints received during town
halls hosted by Senators Dean Florez (D-Shafter) in October 2009. The complaint process is illustrated in the
Findings section of this document.
All complaints filed with the CPUC were provided to PG&E for resolution and expected to either be resolved in
10 days or to provide a required $30 credit to the Customer. CPUC was responsible for communicating results
back to the Customer. Complaints filed with PG&E were handled through the Customer Relations call center
and logged into the Customer's account profile.
The following Figure ilustrates the number of Smart Meter high bil complaints received by PG&E on a monthly
basis.
..&~
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Smart Meter Bil Complaint File Date
350
300
250
200
150
100
50
... cell ~ -"._~_.
.... .....................i..............I...........I.................................................
o
~ ~ ~ ~ 00 00 00 00 00 00 ro 00 00 00 00 00 ~ ~ ~ m m m rn m m rn rn m a a a 0 a a
99 99 ~ 9 99 9 9 9 999999 99 9 9999 9 9 99 ~~~ ~ ~ ~
~ ~ ~~ ~ ~~§~ ~~
~~otzo~~~~~~
~ ~ ~~ æ ~~§~~~
~gotzo~~~~~~
~ ~ ~~ ~ ~~§
~gotzo~~~~~~
II Complaints
Analyzed II Complaints Post Analysis
Figure 7: PG&E-Provided Smart Meter Electric Customer Account Complaints
Structure noted a disproportionate number of complaints filed with the CPUC than with PG&E, as indicated in
the Figure below.
Structure was told by PG&E that a complaint was not marked as a Smart Meter complaint if the Customer did
not mention that they had a Smart Meter. This approach may result in complaints not being accurately coded
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and reported as Smart Meter complaints. Some Customers interviewed indicated that complaints were
registered with both the CPUC and PG&E, although only the CPUC record was identified.
Structure also performed a historical usage analysis utilizing an aggregated Smart Meter complaint inventory
file provided by PG&E. The file included identification of the complaint source, relevant complaints, and
related account detaiL. Structure conducted an analysis of the Smart Meter Complaint inventory to remove
duplicate and non-Smart Meter billng data, and concluded that of the 2,915 Smart Meter complaints that were
filed by PG&E Customers from September 2007 through April 2010, there were 1,378 distinct Customers that
filed complaints related to residential electric accounts. Structure's evaluation included a further detailed
review that evidenced 1,066 represented electric residential Smart Meter Customer accounts.
Subsequent to the conclusion of our analysis, Structure received additional high complaints from both PG&E
and the CPUC. Structure reconciled the lists and determined that an additional 117 CPUC CAB Customer
complaints had been excluded from the PG&E-provided consolidated list. Structure utilized the complaint lists
and supplemental complaints as the basis for our testing selection, but did not include a complete analysis on
these accounts.
As part of a follow-up to the Town Hall meeting complaint process, Structure reviewed the detailed Customer
analysis performed by PG&E and the associated complaint resolutions. The PG&E analysis included a
comparison of the Customer's average daily usage in kWh vs. the monthly average temperature for the region
to demonstrate the trend in usage pre- and post- Smart Meter installation.
Structure reviewed the Town Hall Meeting historical usage profile for each complaint to determine accounts
that were impacted by weather. Structure included the Town Hall complaints within the potential selection
group for the Customer Interviews and in the Smart Meter High Bil meter tests for further validation.
Structure also performed an independent analysis on the high bill complaint Customer accounts by reviewing
the historical usage for 1,378 accounts, and performing detailed analysis on 1,066 accounts. The analysis
performed included:
· Weather impacts on average daily usage
· Average Daily Usage prior month prior year
· Extended biling cycles
· Unresolved complaints
· Cancel/re-bill review
Structure compared the historic average daily kilowatt hours (kWh) usage for each of the 1,066 Customer
accounts with the objective of determining if the high bill complaint Customers experienced increased kilowatt
hour (kWh) usage after installation of Smart Meters due to weather. The comparison utilized the 2006 and
2009 years with similar summer profiles and determined that in 86% of the 2009 complaints, the average daily
usage was less than the 2006 summer although the 2006 summer months were hotter. Structure verified that
the weather in the same July/August period for 2007 and 2008 was 2 to 3 degrees cooler than in 2009. The
remaining 14% of accounts required additional analysis to determine the potential cause for the increased
usage.
Structure also reviewed the average daily usage for the same period of the prior year for each Customer
Complaint account history, and identified less than 6% of the records for the complaint Customers that
exceeded 150% of the same period prior year. Structure utilized the 150% value to reflect the differential in
weather between 2008 and 2009 and focus on identifying unusual spikes in energy usage.
õ~
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Additional complaint analysis focused on the extent to which bills were included in an extended billing cycle, or
delayed bills, outside of the typical (27-32 day) billing cycle. Structure's evaluation discovered that in 2009 and
2010, approximately 9% of the bils reflected a billng period beyond the standard cycle, although less than
0.4% extended past a 45 day window. Extended billing cycles that resulted in higher overall bills were
identified as contributing to high bil complaints. Structure recalculated several bills and determined that the
appropriate baseline adjustments were included in the bills and that the bills were accurately calculated.
Structure also noted that during late 2009 and early 2010, a significant portion of complaints were not resolved
within the CPUC-required 10 day complaint resolution period. PG&E indicated that the resolution time period
extended well beyond the 10-day timeframe due to the influx of complaints during the second half of 2009 and
early 2010. Structure calculated that PG&E took more than 10 days to resolve complaints for more than 67%
of the Customer accounts during this time period. Structure did not review all accounts to identify whether the
CPUC credit for account resolution was provided, but did identify that in several cases where detailed review
was performed, the adjustment was properly applied after Structure's additional review and discussion with
PG&E.
The cancel/re-bils documented by PG&E represented 1 % of the total high bil complaints. A portion of the
cancel/re-bills related to overbiling from estimated meter reads identified by Customers subsequently required
adjustments by PG&E. Billng adjustments were also made to compensate for meter installation issues.
0.4.2.2 Customer Interviews
Structure contacted 100 high-bill complaint Customers for potential in-depth interview participation related to
their high bill complaint. Of the 100 Customers contacted, 20 Customers agreed to be interviewed. Some
Customers permitted inclusion of their information in The Assessment, and permitted Structure to follow up
with PG&E on their behalf. The Customer interviews focused on the nature of the complaint described to
PG&E, PG&E's approach to resolving the Customer's complaint, and the current status of the complaint. The
20 Customers participating in interviews were also included in the field meter testing population.
Based upon Customer interviews, Structure identified gaps in PG&E's approach taken to resolve Customer
complaints, including but not limited to:
· Some Customer complaints were not logged into the service history on Customer accounts.
· Follow-up with Customer was not performed on a timely basis.
. PG&E indicated that account was resolved did not align with Customer perception.
· Lack of resolution communication back to Customer.
. Customer lacked clear understanding of complaint resolution process.
. Customer consistently treated by PG&E as wrong, until the Customer proved to PG&E that they were
right.
· Customer perception of Smart Meter functionality resulted in complaint escalation.
. PG&E front-line customer call representatives lacked professionalism while dealing with Customer
complaints.
. Underlying cause of billing issue not discovered in most cases, even when monetary resolution was
reached.
Recent process changes adapted by PG&E allocated Customer Relations resources focused on Smart Meters,
along with a group focused on resolving escalated complaints. Structure performed a complaint walkthrough
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with both of the PG&E groups and was satisfied that additional focus was being placed on effectively resolving
Customer complaints.
In regards to the CPUC complaint resolution process, Structure noted that the Complaint closure letter
Customers received from the CPUC provided no further information than had been provided by PG&E, and
both were considered to be ineffective.
Structure followed-up on the Customer interviews by reviewing the Customer Complaints with PG&E. As an
outcome of Structure's review with PG&E, two accounts were adjusted based upon the Customer's satisfaction
of certain criteria, including low income CARE eligibility and major customer equipment malfunctions, which
were subsequently repaired by the Customer.
During the interview process, Structure identified discrepancies in the retroactive application of the CARE
eligibility for two Customers. These discrepancies were later resolved by PG&E, following Structure's
inquiries, in favor of the Customer.
Of the 20 Customer interviews completed, Structure identified the following non-unique account issues:
· 9 Customers experienced unusually high bils in the initial months after the Smart Meter was installed
o Explanations identified:
· Estimated meter reads
· Cancellre-bill adjustments
· Weather related
· Usage pattern adjustments
· 9 Customers do not have an explanation, personally or from PG&E, for the spike in electricity usage.
o Potential explanation identified:
· Electromechanical degradation (similar to those found in field testing)
· 5 Customers were on the wrong rate structure, or PG&E changed their rate structure as a result of
their complaint.
o Explanations included:
· Historical premise classified incorrectly, affecting the baseline applied to the premise
· Lapse in CARE qualification, or not registered for lower income-based programs
· 1 Customer experienced a 500% increase in kWhs used after Smart Meter installation
o Explanation included:
· Correction of estimated meter reads.
· Note: The lack of adequate PG&E exception and validation controls resulted in the bill
being processed.
. 2 Customers interviewed experienced electrical problems due to Smart Meters causing "surges" or
interruptions in timed electrical services such as security lights and hot tub pumps.
o Explanations included:
· There is a possibility for a meter in close proximity to FCC Part 15 Unlicensed Radio
Frequency (RF) devices and transmitting data via a 1 watt radio transmitter to create
operational interference (e.g., static, trip, or outage) when the RF signal passes
though these devices. This is an issue that is prevalent with any RF device, such as
walkie-talkies, garage door openers, etc. Electrical issues may be due to a matter of
proximity to the transmitter, strength of the transmitter, frequency of the transmitter,
and the impact on the neighboring device.
· FCC Part 15 Unlicensed RF devices include:
81
Page 31 of 34
9/1/10
ATTACHMEN'l~1 r~agt:~ot 3Lf
0461
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Commissioned by the
&Z Structure™
o Motion sensors
o Garage door openers
o Baby monitors
o Wireless telephones
o Wireless speakers
· PG&E has determined that certain models of Ground Fault Interrupter (GFI)
breakers (such as those used on hot tubs) may be impacted if they are in
close proximity to the meter. PG&E has also engaged Smart Meter
manufacturers to develop low power transmitter solutions to the GFI
interference issue, and has trained the installation contractors to listen for GFI
tripping upon installation of a new meter.
On average, Customers indicated a 4.5 month delay between complaint submission and ultimate resolution.
The quickest resolution was reached in four days; however, the longest resolution took 12 months and
significant effort on the part of the Customer.
While the Customer interviews and related detail account reviews provided significant insight into potential
issues within the Smart Meter program, Structure did not identify recurrent issues that impacted the overall
population of High Bill Complaints analyzed.
D.5 Best Practices Associated with Smart Meters
D.5.1 Best Practices Associated with Smart Meters Findings Summary
Structure found PG&E to have been either historically in compliance, or to have recently come into
compliance, with the majority of industry best practices associated with Smart Meters. Recognizing that some
of these practices have matured over PG&E's three year AMI deployment period, it is reasonable that they
have recently come into compliance with standards associated with best practices. Some concerns were
noted around PG&E's practices related to Meter Deployment, Meter Data Management Interfaces, and VEE.
The following Figure presents a pictorial representation of Structure's evaluation of PG&E's historical and
current adherence to industry best practices.
Page 32 of 34
9/1/10
ATIACHMENT--, Page 3á otl
õ.a
0462
A.07-12-009 COM/MP1/jt2
Commissioned by the
~ Structure™
Structure's Summary of PG&E Best Practice Compliance
. Current li Historical
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Figure 9: Structure's Summary of PG&E Best Practice Compliance
The Findings section of this report addresses the specific areas in which PG&E is historically and/or currently
not compliant with best practices.
D.5.2 Best Practices Associated with Smart Meters Findings Details
Although PG&E was not in compliance with the recommendation to utilize IEC 61968-9 interoperability
standards, PG&E provided documentation that it was employing a set of interoperability standards for MDM
Interfaces.
Of some concern is the lack of documentation verifying compliance with the Meter Deployment best practice to
deploy WAN/LAN collectors prior to meter deployment. By not deploying the communication backbone prior to
meter deployment, the time to transition meter reading from manual to AMI system readings is exacerbated,
extending to an average of 131 days over the implementation period. This allows a continuation of the higher
error rate associated with meter reading and may contribute to the perception that the Smart Meters are
inaccurate.
Additionally, the inability to verify compliance around the Meter Data Management Interface best practice to
"Correlate AMI meter events and alarms with VEE and CiS audits and checks for automated exception
handling" and the VEE Best Practice of "MDMS must provide an on-line method, with workflow, resolving
validation errors rather than reports" has created a situation where there is manual editing of data causing
numerous cancel/re-bills and delayed processing of Customer data. This, coupled with extensive manual,
instead of automated, exception handling of issues has allowed many metering and biling errors to occur on a
repetitive basis, over time, furthering the perception that the Smart Meters are not accurate.
52
Page 33 of 34
9/1/10
AnAcHMENT-Li Page 33 o~
0463
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&Z Structure™
Commissioned by the
California Public Utilites Commission
PG&E has recognized, through the presentation of information, their shortcomings on these issues and has
been actively pursuing remedies such as process improvements and the recent consolidation of the Billing,
VEE, Smart Meter Engineering, and Troubleshooting operations into one Operation Center.
0.6 Security Assessment
0.6.1 Security Assessment Findings Summary
Structure concluded that PG&E has developed a cyber security framework that meets the objectives of the
Smart Grid industry's OpenSG AMI-SEC Task Force "AMI System Security Requirements" that were reviewed
as part of this evaluation.
0.6.2 Security Assessment Findings Details
Structure independently reviewed PG&E's cyber security framework as it applies to their Smart Meter system.
Structure also evaluated PG&E's cyber security framework against industry best practice standards to identify
deviations in current and historical business practices. Structure concluded that PG&E had developed a cyber
security framework that met the objectives of the OpenSG AMI-SEC Task Force "AMI System Security
Requirements" that were reviewed as part of this evaluation. An assessment of the implementation of the
cyber security framework was not within Structure's agreed-upon scope of work
0.7 Other Observations
Structure submitted data requests, using PG&E's standard request procedures as agreed to with PG&E and
CPUC to obtain information used as the basis for this report. At PG&E's request, Structure assigned priorities
to the data requests to facilitate response focus and expedition. While PG&E accommodated the requests,
28% of the requests were substantially delayed due to PG&E's internal processing and legal review. The
delayed resulted in Structure requiring additional time and resources to process, integrate and reconcile
information in an effective manner once received. While Structure does not feel that the delayed information
impacted the results of the Assessment, the receipt of limited data and the differences in data presentation in
the received data impacted the amount of time required to complete the planned analysis, and led to scope
modifications and a revised project completion date of September 2, 2010.
Page 34 of 34
9/1/10
AnACHMENT~1 PageYt of"5cj
12
Readers: SmartMeters interfere with baby monitors, other household gad£
- San Jose Mer... Page 1 of 3
0464
Ilt .Arcurg News
MercuryNews.com
Readers: SmartMeters
interfere with baby
detectors and remotely controlled garage doors.
This equipment operates largely on the 900- to
928-megahert radio spectrum.
monitors, other
"Right about the time that SmartMeters were
installed, our phone went insane," wrote Jane
Meckman of San Jose
household gadgets
This is something PG&E is loath to talk about even
though the company promised transparency when it
By Dennis Rockstroh
[email protected]
brought SmartMeters to our homes.
Posted: 09i06i2010 09:15:39 PM PDT
When Action Line asked PG&E about the complaints,
the utilty said little and put up a bureaucratic
Updated: 09/08/201008:54:55 AM PDT
You've read about problems with PG&E's SmartMeter,
especially the folks who claim it's causing huge
increases in their electrical bils. But that's not the
only issue with the vaunted high-tech device.
As Pacific Gas & Electric's SmartMeter installation
has rolled across Northern California, dozens of
readers have contacted Action Line complaining
about newly found erratic behavior with their
household electronic gadgets. A conflict occurs,
apparently, when the SmartMeter electronically
transmits information back to the utility.
Cordless phones and crib monitors, patio speakers
and wireless headsets are spitting out static and
startling pops and crackles. they complained. Also
affected, they said, are
hurdle to get responses to readers' concerns, going
so far as to require notarized waivers of
confidentiality .
That's the definition of stonewallng.
PG&E knew it had a problem as far back as
early 2009.
"During the second quarter of 2009, PG&E
discovered a limited number of cases of SmartMeter
radio interference with customer electronics," the
company wrote in a report to the California Public
Utilities Commission. The report indicates that PG&E
was working on a solution, but offcially it is mum.
Of course, it is unlikely that all of the problems with
household electronics are the fault of the
SmartMeter. Radio spectrum pollution is all around
us. But the SmartMeter makes a major - and for
wireless microphones, security systems, motion
many people, unexpected -- contribution: When it
communicates with PG&E, it is sending data from a
house to local data-gathering points and back to
PG&E central. Many folks, of course, don't realize
that's happening - until the buzzing starts.
Advertisement
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NETWORK*
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Readers: SmartMeters interfere with uaby monitors, other household gad~
,- San Jose Mer... Page 2 of 3
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MercuryNews.com
Meanwhile the complaints keep flowing in to Action
Line, about 60 so far.
Action Line became aware of the interference when
members of a mothers' group in the Palo Alto-Menlo
Park area started reporting that they were suddenly
awakened in the middle of the night by loud
crackles and pops on their baby monitors. They
suspected their recently installed SmartMeters were
"Your article concerning the PG&E SmartMeter was
exactly what i needed to see," wrote Mario after one
of my earlier columns. "Ever since PG&E has
installed that stupid device, our DirecTV has been
having massive signal issues."
the cause.
i asked PG&E about it. Nothing, at first. I asked
again. Then a month after I asked about this, PG&E
spokesman Paul Moreno said that the families
needed to update their two-year-old baby monitors
Violeta Perez of San Jose wrote that, "Ever since my
SmartMeter was installed, my home alarm system has
been going off randomly."
with improved shielding. (Action Line tip: Make sure
any new equipment you buy is "shielded." Ask to
make sure.) In one case, PG&E paid for a new
monitor.
"A mystery has been solved for us," wrote Veronica
Wong, complaining that her baby monitor has
suddenly picked up static.
Moreno finally responded in an e-mail: "We are
sorry the customer encountered this inconvenience.
The SmartMeter device meets all Federal
Communications Commission standards, so in cases
like this, the baby monitor wasn't built to a standard
where it would not receive interference from legally
transmitted equipment like a SmartMeter meter. It is
likely that the replacement monitor was designed so
it would not receive interference from legally
transmitting equipment, which is why it is no longer
experiencing interference. This reader might want to
seek a refund from the store or maker of the first
monitor she purchased."
Then PG&E started to take a different approach to my
inquiries: stonewallng.
PG&E -- which was dinged by the Public Utilities
Commission last week for its customer service -has handled this poorly. Radio interference from the
SmartMeter and other electronic devices is an
irritating fact of life. But when the company brought
this device into homes without giving us a choice
about whether we wanted it, PG&E owed its
customers an honest discussion of what we could
expect.
Failing to do so has turned an annoyance into a
major pain.
Contact Action Line at actionline@mercurynews.
com or 408-920-5796.
· Move your equipment around to see if you
can find an interference.free spot around
The company decided that written complaints to
Action Line could be responded to only if the
customer signed a waiver of confidentially. "These
either need to be notarized or signed in front of a
PG&E employee at one of our service centers," said
spokesman Matt Nauman.
the house.
. Reorient or relocate the receiving antenna of
the device experiencing the interference.
. Try plugging in to different electric outlets.
. Connect the equipment base to an outlet on
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~ - San Jose Mer... Page 3 of 3
IItJlur
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MeruryNews.com
0466
a different household circuit.
. Consult the dealer or an experienced
radiolT/wave spectrum technician for help.
. If all else fails, you may have to replace the
equipment with "shielded" equipment that is
designed to withstand interference.
Source: FCC
Advertisement
5 9 AnACHMENT~, Page~~
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PG&E SmarMeter Answer Centers and 1 ..&E Open House in Your Community
Page 1 of 1
Terry Dorsey
From: Irma Marquez on behalf of Tony Campos
Sent: Thursday, September 09,20108:24 AM
To: Terry Dorsey
Subject: FW: PG&E SmarMeter Answer Centers and PG&E Open House in Your Community
-----Original Message----From: Lomax, Karla (mailto:[email protected])
sent: Wednesday, September 08, 2010 5:08 PM
To: Lomax, Karla
Subject: PG&E SmarMeter Answer Centers and PG&E Open House in Your Community
Dear Elected and Community LeadersPG&E is committed to educating and increasing our transparency and response to our customers.
One way we are doing this is by increasing the number of SmartMeter Answer Centers throughout our entire service
territory so customers can have one-on-one service to address their questions and concerns. We are also hosting
Open Houses where customers can come in and get information on various PG&E services including billing and rates,
SmartMeter, rebates and CARE programs.
PG&E wil be in your community on the following dates:
. 9/13/10, Scotts Valley Senior Center, SmartMeter Answer Center, 5:30pm-9pm
. 9/22/10 Capitola, SmartMeter Answer Center, PG&E Payment Center (Across from Ross and Kohl's), 1-4pm
. 9/30/10 Watsonvile, SmartMeter Answer Center, Ramsey Park Family Center, 4:00-7:00 pm
. 10/13/10, Santa Cruz County, PG&E Open House, Santa Cruz, 6:00- 9:00 p.m.
We have attached a flyer you can share with your constituents and partners.
If you would like to visit the Answer Center or if you have any questions, please contact Wendy Sarsfield at
[email protected] or 831-784-3584 or Karla Lomax at [email protected] or 408-282-7450.
Thank you in advance for your help!
Regards,
Wendy Sarsfield and Karla Lomax
-:-:Sa ntaC ruzCou nty An swerCenters. pdf::::
***** **** *** ***********
Karla Rodriguez Lomax
Government Relations
PG&E
Direct: 408-282-7450
Cell: 408-206-8744
Email: [email protected]
6;)
9/9/2010
Page 1 of 1
Terry Dorsey
Sent: Thursday, September 09, 2010 8: 18 AM
To: Terry Dorsey
Subject: FW: BaS Agenda 9/14/10
-----Original Message----From: Sandy O'Leary (mailto:[email protected])
Sent: Thursday, September 09, 2010 8:07 AM
To: Mark Stone; John Leopold; Ellen Pirie; Neal Coonert; Tony Campos
Subject: BOS Agenda 9/14/10
I
live in Felton. I wanted to send this email to all of
the BOS. The PG&E put a smart meter on my electrical meter.
Then I found out more about the possible health risks the smart meter may impose. I called PG&E and asked that they
not put a smart meter on my gas meter and locked my gate so they did not have access. The meters can still be read
over the gate. I am wondering if a moritorium will be put in placed. Also, more importantly I would like the smart
meter PG&E put on my electric1 meter removed if there is a moritorium. Please address removing smart meters that
people don't want and replacing the other meter. Thank you.
5Y
9/912010
Page i of 5
Terry Dorsey
Sent: Thursday, September 09, 20108:25 AM
To: Terry Dorsey
Subject: FW: Correction: Smart Meter health alert
-----Original Message-----
From: [email protected] (mailto:[email protected]
Sent: Wednesday, September 08, 20104:59 PM
To: John Leopold; Ellen Pirie; Neal Coonert; Tony Campos; Mark Stone
Subject: Correction: Smart Meter health alert
My apologies. There was a typo in the fourth paragraph of
the letter to Dr. Horton.
September 8,2010
Dr. Mark Horton, Director
California Department of Public Health
Dear Dr. Horton:
i urgently request that you research and take immediate emergency action, issuing a state health alert and whatever
other means are at your disposat to stop Smart Meters.
Wireless Smart Meters are being deployed by utility companies throughout the state of California. The meters have
many substantial problems and issues. However, the most critical issue is the health impact from the microwave rf
radiation they emit.
Utilizing microwave radio frequency radiation, these meters transmit energy usage data from utility meters (water
meters are also planned) directly to the utility company, eliminating the meter reader. They emit brief, very large
pulses as often as every few seconds, 24 hours a day, 7 days a week. As part of a mesh network, they will relay off
each other, so meters will also emit with relayed signals. Southern California Edison gives the power of their peak
pulses as 229,000 microwatts per cm2; PG&E will not disclose theirs (they will only give a time-averaged figure). Our
public exposure standards set by the FCC are 1000 microwatts per cm2, and these standards are very high by
other
countries' standards, and extremely high in terms of what is known about the biological impacts from microwave
radiation (see attached charts - the first entry on the biological effects chart is at 1 ten-trillionth of a microwatt). Our
FCC standards are not protective against cumulative or long-term exposure, nor are they protective against biological
impacts. They are only "considered" protective against short-term exposure and thermal (heating) impacts.(lJ
The frequencies which the electric meters are broadcasting at are ~Q2~9L8 MHz, with the Home Area Network
antenna and gas meters broadcasting at 2.45 GHz. This is pulsed microwave rf.
A study published in 1974 (see below) showed that the most lethal frequencies of continuous wave (CWL not pulsed
(which is more toxicL microwave radiation are 950 MHz (.095 GHz) and L4~ GHz.
The power densities they tested started at .2 W/cm2 = 200,QOO microwatts per cm2. 200,000 microwatts per cm2 kills
rats; the higher power densities just killed them a little faster. "The cause of death has been established as
congestion, hemorrhage, and obstruction of nasal passages and/or congestion, hemorrhage, and often edema of the
9/9/2010
5;)
Page 2 of 5
lungs." (2)
The above mentioned study has this first line: "Despite the vastliterature that exists on the biological effects (1, 2*) of
microwave radiation,. .." Footnote #2 is Zorach Glaser's "Bibliography of reported biological phenomena ('effects')
and clinical manifestations attributed to microwave and radio-frequency radiation" done for the Naval Medical
Research Institute in 1972, with over 2000 documents showing biological effects from microwave and radiofreq u e ncy rad iatio n (http://WWW .m agdahavas, cqniI201Q/Q7/05/pick-of~the-week -1-more~ tha n -2000~dQcurn e nts-
priqr-to-1972-on~bioeffects-of-radio-frequency-radiation/). This was research prior to 1972. And the research has
grown considerably since then. The Bioinitiative Report (www.bioinitiative.org) is a recent review of over 2000 peerreviewed studies on biological impacts from EMF and RF.
Why are we the public and the medical authorities so in the dark about all this "vast" research about something that
has become a fixture of society affecting millions of people - the use of microwave rf in wireless devices?
PG&E (and perhaps the other power companies) makes preposterously false statements on their website regarding
RF (radio frequency). Either they are lying or they are utterly ignorant about this biologically potent, biologically toxic
medium.
People are already getting sick from these meters. I have talked with some of them myself. Symptoms include: heart
palpitations and irregular heartbeat, dizziness, weakness, inability to fall asleep, memory problems and cognitive
disturbances, flu-like symptoms, worsening of existing health problems, emotional distress, agitation, headaches,
hyper-arousal! ADHD leading to inability to focus or relax, nausea, tinnitus/hearing buzzing. Even a PG&E rep, Michael
Herz, has said he gets calls from people who are not feeling well after meters are installed. I wonder how many have
died.
This is an urgent health crisis. If you have been following the international independent research on cell phones, you
will have heard over and over about latency periods for cancers to develop, which don't give us any immediate
feedback. Vulnerable populations such as babies and children, pregnant women, the elderly, and those whose
immune systems are already compromised or are electrosensitive will be the first to react. What will these meters do
in the long term to those who are more resilient? The Russian National Committee for Non-Ionizing Radiation
Protection issued an international alert in 2008 (attached) regarding cell phones and the long-term health problems
for our young people due to their cell phone use. Lennart Hardells study in 2008 showed over a 5 times risk of brain
tumor in those who used a cell phone before age 20 (over 4 times for cordless phone use). He said he feared the
hazards are even greater because it takes decades for most cancers to develop. Researcher Magda Havas has been
publicizing the toxicity issues around Wi-Fi (which Germany warned their citizens about several years ago) including
cardiac rhythm impacts (attached). Wi-Fi, digital cordless phones and microwave ovens also operate at 2.40-2.45 GHz.
Please take action now. Please issue an advisory and use your authority to stop the Smart Meter program. There are
other actions that this state needs to take regarding this situation, but Smart Meters are the first step.
EMF Safety Network (www.emfsafetynetwQrk.org) has a great deal of information on all the issues around Smart
Meters including the health issues. WWIi.electricalpollution.com has additional information on this and EMFs.
I would be happy to answer questions or supply additional information.
Sincerely,
Nina Beety
277 Mar Vista Dr.
9/9/2010
6r
Page 3 of 5
Monterey, CA 93940
IJIJ~netzero. net
831-655-9902
Attached:
Chart: Biological Effects of Microwave Below U.S. & Canada's Regulatory Limit
Chart: International Radiofrequency / Microwave Exposure Standards
Russian National Committee for Non-Ionizing Radiation Protection Warning
Dr. Magda Havas: Wi-Fi and Heart Problems
INTERNATIONAL Radiofrequency / Microwave EXPOSURE STANDARDS
New South Wales, Australia
Exposure Level
(microW/cm2)
0.001
Salzburg, Austria (pulsed transmissions)
0.1
Russia / Bulgaria / Hungary / Switzerland
2 -10
Belgium
3
China
7 -10
Italy / Toronto
10
Auckland, New Zealand
50
Australia
200
New Zealand / Japan / Germany / U.S. / Canada
200 - 1000
United Kingdom
1,000 -10,000
BIOLOGICAL EFFECTS OF MICROWAVES BELOW U.S. & CANADA'S
REGULATORY LIMIT
(microW/cm2) Reported Biological Effects References
· 0.0000000000001 Altered genetic structure in E. Coli Belyaev 1996
9/9/2010
5Y
Page 4 of 5
· 0.0000000001 Threshold of
human sensitivity Kositsky 2001
· 0.000000001 Altered EEG in human subjects Bise 1978
· 0.0000000027 Growth stimulation in Viciusfabus Brauer 1950
· 0.00000001 Effects on immune system in mice Bundyuk 1994
· 0.00000002 Stimulation of ovulation in chickens Kondra 1970
· 0.000005 Effect on cell growth in yeast Grundler 1992
· 0.00001 Conditioned "avoidance" reflex in rats Kositsky 2001
· 0.000027 Premature aging of pine needles Selga 1996
0.001100 Yards / metres from Cell Phone
· 0.002 Sleep disorders, abnormal blood pressure, nervousness, weakness,
fatigue, limb and joint pain, digestive problems, fewer schoolchildren
promoted Altpeter 1995, 1997
· 0.0027 Growth inhibition in Vic
ius fabus Brauer 1950
· 0.0027 to 0.065 Smaller tree growth rings Balodis 1996
0.007 50 Feet from a Cordless Phone
· 0.01 Human sensation Kolbun 1987
0.0161 Mile (L.6Km) from a Cellular Tower
· 0.06 Altered EEG, disturbed carbohydrate metabolism, enlarged adrenals,
altered adrenal hormone levels, structural changes in liver, spleen, testes,
and brain in white rats and rabbits Dumanskij 1974
· 0.06 Slowing of
the heart, change in EEG in rabbits Serkyuk, reported in McRee 1980
0.05 10 Feet /3 meters from a Wireless Computer
· 0.1 Increase in melatonin in cows Stark 1997
· 0.1 to 1.8 Decreased life span, impaired reproduction, structural and
developmental abnormalities in duckweed plants Magone 1996
· 0.13 Decreased cell growth (human epithelial amnion cells) K wee 1997
· 0.168 Irreversible sterility in mice Magras 1997
· 0.2 to 8.0 Childhood leukemia near transmitters Hocking 1996
· 0.3 Impaired motor function, reaction time, memory and attention of school
children, and altered sex ratio of children (fewer boys) Kolodynski 1996
· 0.6 Change in calcium ion effux from brain tissue Dutta 1986
· 0.6 Cardiac arrhythmias and sometimes cardiac arrest (frogs) Frey 1968
· 0-4 Altered white blood cell activity in schoolchildren Chiang 1989
· 1.0 Headache, dizziness, irritability, fatigue, weakness, insomnia, chest pain,
difficulty breathing, indigestion (humans-occupational exposure)
Simonenko 1998
· 1.0 Stimulation of white cells in guinea pigs Shandala 1978
· 2.5 Breakdown of
blood-brain barrier (used a digital cell phone to radiate)
Salford 1997
· 5.0 Leukemia, skin melanoma and bladder cancer near TV and FM transmitter
Dolk 1997
· 2.0 (lower "Microwave hearing" - clicking, buzzing, chirping, hissing, or
high-pitched threshold note tones known) Frey 1963, 1969, 1971, 1973, 1988,
Justeson 1979, Olsen 1980, Wieske 1963, Lin 1978
· 5.0 Biochemical and histological changes in liver, heart, kidney, and brain
tissue Be10krinitskiy 1982
· 10.0 Damaged mitochondria, nucleus of cells in hippocampus of brain
Belokrinitskiy 1982a
· 10.0 Impaired memory and visual reaction time in people living near
transmitters Chiang 1989
· 10.0 Decreased size of litter, increased number of stillborns in mice II 'Chevich
(reported in McRee 1980)
· 10.0 Redistribution of
metals in the lungs, brain, heart, liver, kidney, muscles,
spleen, bones, skin, blood Shutenko 1981
9/9/2010 5;)
Page 5 of 5
· 1,000.0 United States FCC Exposure Limit, Safety Code 6 Canada limit
Meg Sears, Medical Perspective on Environmental Sensitivities, Canadian Human
Rights Commission, 2007.
Cited in Report: Impaçts of Radiofrequency Radiation from Mobile Phone Antennas
Lyn McLean, EMR Australia, 2008
liThe FCC's current exposure guidelines, as well as those of the Institute of Electrical and Electronics Engineers
il
(IEEE) and the International Commission on Non-ionizing Radiation Protection (ICNIRP), are thermally based, and do
not apply to chronic, nonthermal exposure situations. They are believed to protect against injury that. . . result(s) in
tissue heating or electric shock and burn. . . The FCC's exposure guideline is considered protective of effects arising
any
from a thermal mechanism. . . the generalization by many that the guidelines protect human beings from harm by
and all mechanisms is not justified." (my emphasis)
Norbert Hankin, U.S. Environmental Protection Agency, 2002
http://wWW. emrpo I icy. 0 rg/litigati 0 n/case_1 aw/dgcs/noi_ePL resp9Dse.pdf
(2J http://www.magdahavas.com/2010/09/Q6/p ick~of- th e-week-9-0~95-anq~2A5-ghz-most -letha I-niicrowave-
frequenci~M
Polson, P, DCl Jones, A Karp, and JS Krebs. 1974. Mortality in rats exposed to CW microwave radiation at 0.95, 2.45,
4.54, and 7.44 GHz. Final Technical Report Prepared for U.S. Army Mobility Equipment Research and Development
Center, Fort Belvoir, Virginia, Contract DAAK02-73-C-0453. 105 pp.
9/9/2010
5Y
To:
From:
Re:
Date:
County Board of Supervisors, Santa Cruz County
Todd Glassey CISM CIFI, CTO Certichron Inc
Key issues with SMAR TGRID and SMART METER Operating Models
9/9/2010
This letter constitutes a formal motion to the Board as an ex-parte community-based
submission. It pertains to the adoption of policy within the County and setting of
ordinances for the roll-out and operation of SmarGrid and Time Of
Use billing systems.
The SmartGrid
The SmarGrid is a hodge-podge of next generation systems which are penetrating the
existing power and infrastructure service markets in America and globally. The
SmartGrid is then a next-generation use of an upgraded power distribution grid to allow
more intellgence and automated management practices to be used in operating the
electric, gas and water utility systems (and interestingly enough as well as steam where it
also is sold by the thermpsi model). It is expected also that the new technologies wil
create more options and better use telemetry for the end users as well as reduce the
physical account-support costs associated with provisioning and management of
the
meters and their information collection. As such they wil make power company's
significantly more profitable which is one of
the driving factors for deploying them.
The SmartMeter is a mini-ATM functionally
What the SmartGrid is in fact is an automated transaction gateway and infrastructure for
delivering utility-services as consumable-content just like any other network which
connects the end-user to the local 'grid'. In fact the Meters themselves already connect to
appliance type computer systems or in the case of the really "smart" SmartMeters already
have these capabilities integrated into them.
In doing so we must ensure that the consumer's rights and the integrity of
the operating
model is properly vetted and to date that is not happening. What that means is that power
company's are discovering that how they install and how they calibrate their meters is
now a key factor in whether they are believable and whether the public confidence is
there or not for the program.
SmartMeters benefit the power company's much more than the consumer
As we noted above, in the county of Santa Cruz the deployment of the new SmartGrid
Meter Infrastructure (called AMI - Automatic Metering Infrastructure in the utility
world) will save the power company's milions of dollars in maintenance and
provisioning overhead (this is what it costs the power company to send a human to your
site and to provide those human based services directly). While it is true that the
SmartMeters wil allow paries to better judge their usage they do not really provide any
*5J
./
mechanism to allow a choice of electrical providers since Direct Access programs don't
serve the public only commercial or incorporated entities who can qualify as a
commercial power user are allowed to participate in the program so the argument that the
meters give the consumers choices is in fact very misleading.
Most SmartMeter systems fail basic digital evidence rules
The SmartMeter systems are easily spoofed and can be jamed such that the collector
radio's are useless. Further they can be made to send bad collection data regularly
because the meters use poorly designed security. One meter we looked at had so many
security holes it could be reset from a radio through a supervisor session which had no
password or any controls. This mode would never be used in production but stil
functioned so it created a security hole in the deployment of about 20M meters already in
use. Bad testing and no standards for deployment are the issue here.
That said most existing SmartMeter devices and their infrastructure fail any semblance
of the network security models already mandated for all other financial transaction
controls in the US and at State levels meaning that they are unreliable and untrustworthy
based on California Digital Evidence standards like those created in California v Khaled
and the 4th Appellate Districts appeal which now enforces integrity requirements for any
digital information which would be used as evidence in a court proceeding". What that
means is that the CPUC is formally aware of
the short fallings of
the existing
SmartMeters per the Khaled ruling and are taking commentary on it under Proceeding
PI 007015 fied last month.
. Meters are commercial devices and probably need to also be regulated under
County Weights and Measures certifications as well.
So it is our assertion that the deployment of these systems must meet the minimum
security standards for basic network models. That means the design of the SmartMeters
themselves is what must be proven and to date there is no such qualitative review of their
operations. For instance can a SmartMeter be reset or its collector radio spoofed? If so
how easily is this accomplished and are plans or commercial devices which would spoof
these available like GPS and Cellular Jamers have become? The issues of privacy of
data as well becomes critical since these are in fact purchases of commodities which are
the content-energy units delivered to the consumer.
Santa Cruz County's response
We believe that the easiest way for the County to end the questions and push-back on
SmartMeters is to simply inform any and all parties that per Khaled and other evidence
standards that any system which is deployed must produce evidence which is competent
and trustworthy under mandates set in the California Appellate Cour already.
The adoption of
this mandate wil functionally stop all roll out of SmarMeter operations
until such time that the CPUC has formally ruled that these systems meet the minimum
evidence competence necessary to facilitate the use of their evidence in a commercial
dispute or criminal prosecution for the theft of energy or frauds relating to the delivery of
energy and mis-reporting therein.
Our belief is that most Utilities and most SmarMeter providers haven't really thought
through the issues of evidence and trustworthiness of their systems and that they stil live
in the "Because I said so" world that was in fact debuned when the Wizard of Oz was
released and something they stil strive to hide from.
We therefore propose the adoption of a resolution "to enforce strong digital evidence
standards on any systems which provide financially impacted services to an end-user as
par of any use or delivery transaction". We also propose that these include a Khaled
review for the use which the Utilities would then file with the County assuring the Board
of
Supervisor's of
the Evidence Competence of
their new Energy-Use Billing and
Metering Systems in properly serving the public interest.
And finally we propose that the County formally enact an ordinance that SmartGrid
devices which provide measured delivery of services at specific time do constitute a
resource which can be regulated as a weights and measures certification requirement in
the County of Santa Cruz itself and that the effect of these two resolutions wil answer all
of the public's concerns for SmartGrid as well as put in place a framework for controlling
and regulating the SmarGrid in Santa Cruz County.
il
~~laSSey CISM ClF
CTO Certichron Inc.
800-511-2301
50 W. San Fernando St
Suite 320
San Jose CA 95113
[email protected]
PG&E's history of blowups I San Francisco Ba,
PG&E's history of
iardian
http://www.sfbf
i/poli ti cs120 1 0/0911 O/pges- his tory- blowups
blowups
09.10.10 - 8:28 pm I Guardian Staff Writers (lca'egory/author/guardian-staff-writers) J (3)
14 _(nll"~lj~:..i:g,e22.9!1._Ç2,rr.!s,b,~!£_nP'?MY,::,IiJ:p_o~.3.A,~,f..%!~,E~:"ê,!I.9,:,9:m'M,:?,Ep'QEtigs,~~E491Qr~~fQ.e,~,ff1~,*ffpg~.1d:i,i,st.Qry,:.
l:!.c:,\'l,p,s,~,t:lG,,%.fß"E~1~~i~.Q"tiLstQ,I'y°6i"?9Q.f.~,~QI;)Q~yps%lQ%LQ%,~Q"S~D_%f_QfEi:D.2j,Sgc:"4.4QEI~y,~4.~QGJ::i,~gti¡i.I*"Sig=Sp)
By Noah Arroyo
We don't yet know if the San Bruno fire is a b.rrificjlCcide."
or an equally horrific mistake ihtto:!JW\V'Nh3yc1tlzen,Ol'c;!stlti..bl'UI:"
ej;T,:lo~,,,lon¡st()r\i)eX')e;ns \\li,:IC.jh-oossit)!tH::ausesF¡ . But Pacific Gas and
Electric Company, which owns and operates the gas line
that ruptured, has a history of incidents that look a lot like
this one. Some of these incidents have caused power
outages. Others have blown things up, or injured people.
The company also has a history taking money that ought to go to maintenance and
diverting it into fat corporate profis.
In December of 2003, a cable fire at the Mission Substation of the Golden Gate Control
Center caused a more than 100,000 people to lose power. The California Public
Utilities Commission inspected the incident and found that PG&E suffered from general
procedural
laziness, and that "PG&E failed to follow three recommendations made in
its 1996 Root Cause Analysis Report following (a)
1996 fire."
At the time, San Francisco City Attorney Dennis Herrera noted: "The evidence is clear
that PG&E knew about problems that endangered public safety and threatened to cost
San Francisco businesses millions-and yet did nothing to fix them."
Then, in August 2005, sornethinq exploded underqround the intersection of Kearnv
and Po s t (http:! íwww.sfqate.com/cqi..b1nh:-rticle.co¡.ìfi le:;/ c/ a¡;;~QO,5iQJ)t! SHEtAsf 2/0 los iOo.:t;lJ. A
manhole cover shot into the air and the escaping fire severely burned a passer by. The
event's catalyst was a failed transfor¡ner ovlnecJs1iiçQIJi?@!egJ2YlG_I;L
¡ 1-: ltD: JlWV/V,i poe. com! about/news/Il ed iarela lion Sin~;\;vsreleases!a:3 2Q05/OS0Ü 19, s I,tm I) .
In June last year, a fire peeked and then roared from a nim:ihole
Lt1t~"~y,', foq(~\~il~Q'§.L comhN9rdpressÛ:p09'¿Q!~l?ge-v al.l.e:s'?~:t2QQ,~,Y0,tl_y L£~:pq,YYi~FD,with enoug h
force to resemble an explosion to onlookers. The electrical fire, at O'Farrell and Polk,
was coming from a PG&E vault. The impact? 8.6DO cus(Q.rels !OSU!(jwt?C
fhtt¡\/hN\fvV/,kt'ju,comínewstI9670705/de!aiLhtniiì. This, like Th.ursç@l~s flI~,at,SanJ2ßL:iQ
¡: ri ttD: l/www,LlC:ycítlzcn.o¡-9Isan-bruno-exp los lon/stcrv/huqe-eXF.lío sion-res ¡(.lent ;;:.1 :':::)1, 'fJn:no!) , was a fi re
bigger and more resilient than what emergency responders at first assumed. At least in
2009, nobody died.
Another difference: In 2009, leading up to the explosion, t§.~EÆ¡lJtL~Q.\!ab(jIJt the
pro ble m beta reh a nd. (r-)t tp .llw'NV'¡, baVCilízeri. cHq/san-bruIlO-(j,¡;:iiO;:;!OIìisli)ri/re;;:;:jf'riis-:-eooitE:C!
leak....d;,ws-explosjoo! )
Why hadn't PG&E replaced this natural gas pipe (the San Bruno fire's origin) ~
installation in 1948? (htto:l/ww\v t::ôvciuzcn.(¡((J!S8n..bruno,.t:xciOê;; ìnistcivhes.¡dent "¡'¡C,'Dorti,:;d,j,,c:akdays
,"xDlos!"n/) Was the problem one of cost? If so, would replacing such a pipe cost more
than the $46 million the company spent trying to p.\I.~Lr~U¿PQsitionJ_§.
2 of 3
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91131101:53 PM
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Southern California -- this just in
" Previous Post I I ,.A. NOW Home i Next Post"
PG&E did poor job inspecting gas pipes,
advocacy group says
September 10,2010 I 4:08 pm
PG&E has had extensive problems with a program to inspect leaks in a massive distribution system that
stretches from the California-Oregon border to Bakersfield, according to a ratepayer advocacy group.
Distribution pipes, which deliver natural gas to neighborhoods and individual homes, are smaller in
diameter and operate at less pressure than the giant transmission pipes such as the one that exploded in San
Bruno.
"Gas Leaks, Gas Leaks Everywhere" was the subheading in written testimony submitted June 11 to the
California Public Utilities Commission by William Marcus, an expert witness who commented on PG&E's
current rate increase proposal on behalf of the Utility Reform Network, a ratepayer advocacy group.
The utility, he said, has not been forthcoming about its poor inspection record because it "is afraid of
negligence lawsuits in the event of explosions due to previously undetected leaks," he said.
PG&E do not immediately reply to a request for comment.
Marcus said he was able to get some insight into the program's difficulties -- including poor training of
inspectors and falsification of records -- because the PUC's Utilities Safety and Reliability Branch released
a PG& E PowerPoint presentation that noted that a 2007 re-survey of leaks in the North Coast Division
"found deficiencies" including "record falsification" in earlier surveys performed in 2004-07.
NI
At one point, the survey had to be "suspended" and all personnel retrained. Surveys made using special
optical equipment showed that operators were not qualified and had to be retrained. Results of a "statistical
sample survey" revealed that all eight out of eight samples in the Yosemite area "did not meet criteria."
Four our of four were subpar in the Peninsula; four of eight in the Sierra; eight of eight in the North Valley;
and four of four in Fresno, the presentation said.
A 2008 leak survey showed better results, PG&E said.
The report concluded that "system-wide improvements needed in leak survey" in the areas of "leak grading
process, standards, controls training and operator qualification."
As a result, the company had to resurvey "all facilities previously surveyed in 2004, 2005, 2006 and 2007."
The extra work will cost $103 million in unexpected resurveys by the end of 2010, Marcus said.
PG&E is working on a response to the information. PG&E's lackluster distribution inspection record could
be indicative of the kinds of problems that led to a fatal gas explosion Dec. 24, 2008, in a residential
neighborhood of Rancho Cordova, a Sacramento suburb, Marcus said.
The gas leak in a distribution line killed one person and injured five. The National Transportation Safety
Board concluded that the probable cause of the explosion was the use of substandard pipe. The line
included "a section of unmarked and out-of-specification polyethylene pipe with inadequate wall thickness
that allowed gas to leak from the mechanical coupling installed on Sept. 21,2006," the NTSB reported.
A contributing factor was the two-hour-plus delay in the arrival of the scene of a PG&E crew that "was
properly trained and equipped to identify and classify outdoor leaks and to begin response activities to
ensure the safety of the residents and public," states the NTSB report adopted on May 18,2010.
"There were several mistakes made," Marcus said.
An earlier 2006 repair of the same line was faulty. "Instead of poly pipe, they installed the sleeve it was
packaged in. Of course, it leaked," he said.
Marcus also faulted a PG&E employees for making an initial inspection of the scene but not ordering
people to evacuate their homes.
-- Marc Lifsher
!S
-
http:/ N.mantecabulletin.com/news/article/ 16917/
By Dennis Wyatt
Managing Editor
209-249-3532
POSTED Sept. 11, 20103:39 a.m.
d [email protected]
209-249-3532 CPUC can't be trusted to investigate PG&E
explosion in San Bruno
The California Public Utilities Commission should not investigate PG&E for the
killing of four people, maiming countless others and destroying 37 homes in San
Bruno.
They ca n't be trusted.
If you doubt that, reference the scathing National Transportation Safety Board
report in an eerily similar natural gas line explosion on Christmas Eve 2008 that
killed a Rancho Cordova man. The NTSB ripped PG&E apart for its lackluster
maintenance and protocols that essentially gave the hardworking front-line PG&E
employees a next to impossible task to stay on top of system needs.
There wasn't so much as a whimper out of the CPUC after that. True, there was
the usual chest beating from the CPUC media office about how they were going
to keep PG&E on their toes. But as San Bruno has now tragically proven PG&E
apparently doesn't put much stock in customer concerns about maintenance
issues nor does the CPUC want to use its regulatory teeth except for show.
It's convenient, in a way, that the CPUC's general counsel Frank R. Lindh labored
just a few years ago as general counsel for - surprise, surprise, - PG&E.
The CPUC also routinely approves massive rate increases for PG&E that are often
based on the San Francisco-based utility's claim they will use the money to do
routine maintenance and then siphon the funds collected from ratepayers for
other purposes. One recent rate increase application the CPUC approved
included money to replace 40,000 aging power poles. An audit done several
years later showed that PG&E only replaced 4,000 poles. How it came up was
PG&E had the gal to ask for another rate increase to replace the poles that
weren't replaced with the first rate increase.
Is there a pattern here?
The corporate honchos cannot place this at the feet of PG&E line workers who
1 of 3
9/13/101:59 PM
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http:/ v.mantecabulletin.com/news/article/ 16917/
they keep squeezing so they can improve short-term profits.
And it isn't the case of asking PG&E to "overfund" work crews. Consider what
happened during the boom days earlier in this decade. It would take upwards of
a year to get PG&E work crews to various projects because corporate PG&E had
cut staffing so thin. If you doubt that ask Jerry DeGroot who was delayed for
almost a year trying to open his retail complex in the 200 block of North Main
Street or cities such as Manteca that often have seen projects delayed for
months because PG&E couldn't meet promised deadlines to relocate power
poles. This work, by the way, is not funded by ratepayers but by those
requesting the work.
PG&E has a history of responding to legitimate concerns about safety by doing
what it does best - threatening to sue.
South San Joaquin Irrigation District found this out when PG&E tried to push a
24-inch natural gas pipeline through district easements earlier this year without
going through the same environmental review process that everyone has to go
through.
PG&E's initial response on the corporate level wasn't to cooperate or address
concerns but it was to threaten to sue if they weren't allowed to proceed
immediately. SSJID did not back down and got the assurances - and
specifications - they needed to make sure district water was save from being
polluted and that their constituents would be safe.
San Bruno is a classic case as to why some argue we don't have enough
regulations on certain types of businesses in California. Of course, PG&E is not a
true "free market" business. They are protected and propped up by guaranteed
rates of return by the CPUc. It is not like Wal-Mart, Kmart, and Target going
after business head-to-head. PG&E operates as a quasi-government agency that
is able to funnel big bonus checks to its top corporate leadership even within
months of teetering on the edge of bankruptcy and sending rates sky high while
rank-and-file workers see their paychecks shrink.
In other words, they were even ahead of Wall Street in the audacity game of
almost driving a company into ruins and then rewarding the executives who
were at the helm.
San Bruno, unfortunately, is the end result of the game PG&E is playing and the
lapdog known at the CPUC that serves them and not the ratepayers who are at
20f35~
9/13/10 1:59 PM
http:/ N.mantecabulletin.com/news/article/ 16917/
PG&E's mercy.
http://www.mantecabulletin.com/news/article/169 17/
3 of 3
9/13/101:59 PM
CBD BOSMAIL
from: [email protected]
Sent: Monday, September 13, 2010 3:00 PM
To: CBO BOSMAIL
Subject: Agenda Comments
Meeting Date: 9/14/2010
Item Number: 52
Name : Marilyn Garrett
Email: Not Supplied
Address: Not Supplied
Phone: Not Supplied
Comments:
Please add my following comments to the 9/14/10 Agenda Item 52:
1) Urgency ordinances have been successfully implemented in the town of Fairfax (8/4/10) and the City of
Watsonville (8/24/10). These urgency ordinances have proven to be extremely effective in immediately
halting PG&E from installing "Smart" Meters. For instance, a Sept. 9th, 2010, memorandum from the
Watsonville's City Attorney Office, Alan J. Smith, to the City Manager, Carlos Palacios, states that "a
P.G.&E. representative reportedly said that P.G.&E. has administratively decided to defer its replacement
program in Watsonville and the few other cities that have adopted such an ordinance for the time being." I
am voicing my strong support that the Santa Cruz Board of Supervisors immediately implement a similar
urgency ordinance.
2) i also urge the Santa Cruz Board of Supervisors to extend the ending date on the proposed urgency
ordinance from Dec. 31, 2010, to at least one year from the date of enactment (as done by the City of
Watsonville). I believe that a period of at least one year is necessary to adequately investigate the health
dangers and accuracy problems of these microwave radiofrequency devices.
3) In addition, as a resident of this county, I formally request a list of the locations of all P.G.&E. "Smart"
meter infrastructure and antennas, along with the emission levels and purpose of each location.
Furthermore, I demand the immediate removal of all non-permitted devices that have already been installed
in the County of Santa Cruz.
4) Furthermore, the horrific deadly gas explosion in San Bruno 9/9/10 is only the most recent in a tragic
P.G.&E. history. According to the San Jose Mercury front page article on 9/11/10 called "PG&E safety and
training record called into question" by Paul Rogers and Steve Johnson, P.G.&E. has a proven track record
consistently destructive to our health and environment. Reports exist of "Smart" Meter gas and electric
explosions. Therefore, P.G.&E. cannot be trusted, criminal investigation is in order, and their "Smart" Meter
program must be halted now before significant harm can be done to our community.
9/13/2010
5)-
CBD BOSMAIL
"'~~~~~'"~-~~-~-""~-..-"'-
From: [email protected]
To: CBO BOSMAIL
Item Number: 52
Name: Mahlon Aldridge
Address: PO Box 1188
Phone : 831-426-5925
Comments:
September 13, 2010
Dear Supervisors,
I'm writing to express Ecology Action's support for the deployment of smart meter technology as quickly as
possible, to articulate some of the key benefits of the technology, and to emphasize the need to
appropriately address public concerns about health and accuracy.
Smart meters are a centerpiece in realizing a market-driven sustainable energy system in California. They
allow energy consumers to make strategic consumption choices, save money and reduce carbon emissions
by better understanding when and how to use energy. While necessary regulations and technology
continue to be phased in, smart meters are essential to our transition to a clean energy economy.
Smart meters are also a central technology to the widespread adoption of electric vehicles. The meters will
allow
a customer to buy nighttime off-peak electricity at lower prices and potentially to sell excess electricity
from the vehicle's battery back to the grid during peak hours when prices are higher. By making a profit on
the transaction, the economics of owning an electric vehicle become much more compelling.
Smart meters are an enabling technology for reducing the carbon emissions of California's vehicle fleet.
California's wind power is most abundant at night. However, there is little market for night-time power, thus
the low carbon benefits of wind power can go unrealized. As a related example, in Las Vegas it is estimated
there is the capacity to power 300,000 electric vehicles with nighttime electricity that is currently not being
utilized. By making it possible for consumers to buy cheap, clean power at night rather than dirty daytime
power, smart meters are key to drastically reducing the carbon-per-mile output of our transportation system.
Smart meters also allow for accurate measurement the time and quantity of energy that a customer delivers
back into the grid from on-site renewables (e.g. PV, wind, and micro-hydro); thereby assigning that energy
input the highest possible value.
9/13/2010 i7
A sustainable energy future depends on deployment of smart meters in a way that successfully
accommodates the need for technical accuracy and an understanding of any potential human health 5-'1 _
impacts. Ecology Action believes d Dyment must not wait and should L lone concurrently with the
continuing work on safety and accuracy.
Sincerely,
Mahlon Aldridge
Vice President
Ecology Action
3d
9/1312010
caD BOSMAIL
To: CBO BOSMAIL
Item Number: 52
Name : Reba Nielsen
Email: Not Supplied
Address: Not Supplied
Phone: Not Supplied
Comments:
The health-damaging effects of electromagnetic radiation have been known for 75 years. The article which I
have included below is from the IRCHET International Research Centre of Healthy and Ecological
Technology (Berlin-Germany) and gives a chronological history of scientific research studies on the subject
of microwave radiation. Therefore, in light of all of this scientific evidence, I am voicing my opposition to the
installation of "Smart" Meters in Santa Cruz County and urge you pass the proposed urgency ordinance.
(Article from ww. hese-pro ject. org/hese-uk/ en/niemr/hechtvortrag070 724eng lisch. pdf):
Overloading of Towns and Cities with Radio
Transmitters (Cellular Transmitter): a hazard for
the human health and a disturbance of eco-ethics
Karl Hecht, Elena N. Savoley
IRCHET International Research Centre of Healthy and Ecological Technology
Berlin - Germany
1. A Very Serious Warning 36 Years Ago
"The electromagnetic radiations emanating for radar, television, communications systems,
microwave ovens, industrial heat-treatment systems, medical diathermy units, and many other
sources permeate the modern environment, both civilan and military."
"Unless adequate monitoring and control based on a fundamental understanding of biological
effects are instituted in the near future, in the decades ahead, man may enter an era of energy
pollution of the environment comparable to the chemical pollution of today."
"The consequences of undervaluing or misjudging the biological effects of long-term, low level
exposure could become a critical problem for the public health, especially if genetic
effects are involved."
These quotations are excerpts from the US government report "Program for Control of
Electromagnetic Pollution of the Environment", which was published in December 1971. The
government report was drafted starting in December 1968 by an expert group made up of nine
people, "The Electromagnetic Radiation Management Advisory Council". "The President's
Office of Telecommunications Policy" issued the order. This report was an urgent warning for
the future.
9/13/2010
5)-
2. Today (2007): Ignoring This Wariiiiig and Irresponsible Deception
About 36 years have passed since the publishing of this report. Unfortunately, this urgent
warning, which is scientifically well-founded, is currently not taken seriously. The beauty of
landscapes and cities are spoiled with "forests of radiant radio antennas" in order to serve a
new addiction of people: telecommunication. From this unethical, environment-disfiguring
antenna forest, people are continuously bombarded by invisible, imperceptible, healthdamaging, stressing,
high-frequency, electromagnetic radiations.
As predicted 36 years ago in the US government report, our planet today is more
"contaminated" by "electronic smog" than with the chemistry that already heavily strains
people. Those responsible have unfortunately still not considered a possible double strain of
these two harmful factors.
The telecommunications and microwave industry even contends that these high-frequency
electromagnetic radiations are not harmful for people's health. That is irresponsible deception.
Facts support the opposite.
3. Radio Wave or Microwave Sickness Known for 75 Years
Seventy-five years ago in August 1932, the German doctor Erwin Schliephake published
scientific data in the German Medical Weekly about radio transmitter-induced "microwave"
or "radio wave sickness" with the following symptoms: severe tiredness and fatigue during
the day, fitful sleep in the night, headaches to the point of intolerability, and high
susceptibility to infection.
These symptoms, which are also observed in neurasthenia (enervation), were not to be traced
back to the thermal effects, but rather to the athermal effects of high-frequency
electromagnetic radiation, according to Schliephake's view. The health-damaging effect of
high-frequency electromagnetic and electric radiation was reproduced in thousands of
investigations.
This microwave sickness, induced by athermal high-frequency EMF radiation, was verified
by the scientific work of the Russian author Zinaida Gordon from the Moscow Institute for
Industrial Hygiene und Occupational Diseases, in 1966 in the Russian language and in 1970
in the English language, among many others. She examined more than 1,000 workers who
worked at radio installations, electric utilities, radar stations, etc., over the duration of
10 years. She established the following symptoms:
? daytime tiredness? neurovegetative disorders
? loss of productiveness? neurosis
? sleeplessness? depressions
? headaches? hyperactivity and inner agitation
? cardiovascular regulation changes of various types
According to Prof. Gordon (1966), the symptoms strengthened with increasing duration of
exposure, and sensitivity to the microwave radiations increased.
Reports from Poland were presented by Baranski (1971, 1967, 1966) and Czereski et al.
(1972,1964) about:
? microwave syndrome and
? chromosome damage, and by
Minecki (1967,1965,1964,1963, 1961) about:
neurovegetative disorders? chromosome damage
? psycho
? neurasthenia? embryonic development disorders
after the chronic influence of weak high-frequency fields.
Karel Marha, from the Institute for Industrial Hygiene and Occupational Diseases Prague
(1968-1971), reported about analogous symptoms, like they had already been described by the
others. He stressed, though, that the brain functions are especially sensitive to high-frequency
electromagnetic radiation.
the title
1969, eleven large conferences took place under
In the USA from 1955 until
9/13/2010 !5r
"Microwaves - Their Biologic Effects dnd Damages to Health". The so-cai. _J Richmond
Conference in 1969 presented such overwhelming facts that the above-mentioned government
report had to be compiled. Besides the microwave symptoms mentioned, gastric bleeding,
leukemia, chromosome breakages, cancer, and clouding of the eye lenses were also observed
by doctors in the USA.
Already in November 1958, the "Security Measures for Persons in the Range of Microwave
Generators" was instituted by order of the Minister of the Soviet Public Health Service.
4. Eastern Threshold Value Around Three Orders of Magnitude Lower than Western Threshold Value
The threshold value was established at the value of 0.01 mW/cm2 for full-time contacts with
high-frequency electromagnetic radiation, based on research results in Russia (the former
Soviet Union).
The threshold value was bindingly stipulated at 10.0 mW/cm2 in the USA at the 1955
conference at the Mayo Clinic in Minnesota. With the establishment of NATO, this threshold
value became binding also for Western Europe. This difference of three orders of magnitude
between the threshold value in the East and the threshold value in the West still exists today.
In the East, electrical smog is taken more seriously.
The annual report of the national Committee of Russia for non-ionizing radiation of the year
2002 addressed the following themes among others:
? "Emotional stress and EMFs" (electromagnetic fields),
? "Electromagnetic Fields and Cancer",
? "The State of Health and Work Conditions of Workers in Civil Aviation Who Operate
Radar, Navigation, and Communication Equipment",
? "The Functional Brain Hemisphere Asymmetry Under the Influence of Magnetic
Fields".
They adopted the following recommendations for the protection and safety from mobile
telephone use: mobile telephones should not be used by children under 18 years old,
pregnant women, patients with neurologic diseases, neurathenia, psychopathy, neurosis, sleep disorders,
memory loss, or epilepsy syndrome.
Basically, it is recommended to keep mobile phone conversations as short as possible and in
no case to have a conversation longer than 15 minutes.
5. Research into the Findings in the Russian-Language Scientific Literature Shocked German Authorities
Prof. Dr. Karl Hecht and his associate Hans-Ullrich Balzer were commissioned in 1996 by the
Institute for Telecommunication to carry out research on the Russian
technical literature about the health-damaging and biological effect of high-frequency
German Federal
electromagnetic radiations from the years 1960-1996. In 1997, the authors turned over the
report, which was based on 878 scientific works, to the sponsor. The data was so
overwhelming for the German conditions that the report immediately disappeared into the
archive.
6. The Duration of the Effect of High-Frequency Electromagnetic
Radiation - Decisive for Health Damage
Next we would like to mention a few important facts of this report. The duration of the effects proved to be a
very decisive factor for the health-damaging effect of the EMF. A three-phase progression in the
development of the microwave syndrome was proved.
First: Initial Phase
In the first 1-3 years, predominantly a sympathicotonic deflected initial phase was
predominantly demonstrated, which proceeded in three sub-phases:
First Subphase = Pronounced sympathicotonia (hypertonia) activation phase. This phase is
comparable with the alarm phase of the general adaptation syndrome of Selye and with the
9/13/2010
5r
unspecific activation according to Lii iusley (1951), Lacey (1967), and othb....
Second Subphase: Performance-promoting, increased sympathicotonic reaction phase in the
sense of a eustress reaction or an emotional activation (Lindsley 1951). According to Selye
(1953), it is to be interpreted as a resistance phase.
Third Subphase: Adaptive, balancing phase with less sympathicotonic deflection. The body
functions are still
located in the range of homeostasis, so normal values are measured,
although latent, intermittently appearing ailments may already express themselves. This
phase, too, is still to be assigned to the resistance phase, according to Selye (1953).
Second: Pre-Morbid or Early Phase of a Chronic Disease
After 3-5 years of influence duration, weakly visible and/or strengthening pathologic
developments of neurasthenic basic symptoms with vagotonic reaction tendencies, sleep
disorders, and daytime tiredness appear.
Third: Exhaustion Syndrome
Pronounced neurasthenic symptoms with increasing pathologic lapses of the regulation
system, neurotic and neurasthenic symptoms, sleep disorders, daytime tiredness, and general
exhaustion are dominating appearances. Effect duration ~ 5 years.
Figure 1. Schema of the stages of illness development after long-term influence of EMF radiation in
comparison with the stages (1,2, and 3) of the General Adaptation Syndrome according to Hans Selye
(1953).
I = activation phase, A = activation (excitement), B = positive stimulation, C = adaptive phase; II = latent,
weak
pathologic development; ILL = strong pathologic development. Based of the findings of a literature review
(Hecht und Balzer 1997).
7. Essential Findings after Long-Term EMF-(EF-)Effect
Objectively gathered findings:
? neurasthenia, neurotic symptoms
? EEG changes (decay of the alpha rhythm into the theta rhythm and isolated delta
rhythm)
? sleep disorders
? deformation of the biologic rhythm hierarchy
? disorder in the hypothalamohypophyseal adrenal cortex system
? arterial hypotonia, more rarely arterial hypertonia, bradycardia, or tachycardia
? vagotonic displacement of the cardiovascular system
? hyperfunction of the thyroid? resting tremor of the finger
? potency disorders? hair loss
? digestive function disorders? tinnitus
? slowing down of the sensory motor
system
? increased susceptibility to infection
Subjective Complaints:
? exhaustion, lack of energy? weakness of concentration
? daytime tiredness? headaches
? quick tiring under stress? lightheadedness
? constriction of physical and mental ability
? concentration and memory decline
? night sweats
? spontaneously occurring excitability from hypotonic reaction situation, especially in
the case of external pressures
? cardiac pain, heart racing
(Rubzowa 1983; Rakitin 1977; Drogitschina et al. 1966; Gordon 1966; Drogitschina und
Sadtschikowa 1965,1964; Piskunova und Abramowitsch-Poljakow 1961).
9/13/20105r
8. Factors That Can Influence the Development of an Illness through
Athermal/Biologic, Non-Ionizing EMF Radiation
Duration of Influence: At the earliest, pathological appearances appear after ca. 3 years; duration of
influence;: 20 min. daily, 5x per week has no pathological consequences.
Age: Younger organisms show greater electromagnetic sensitivity than older ones; children especially must
be protected.
Individual State of Health Electromagnetic Sensitivity: decreasing healthiness increasingly
raises electromagnetic sensitivity
Status of the Elektrolyte/Mineral Balance: lack of minerals and toxic stress increases
electromagnetic sensitivity.
Additional stressor effects, e.g. noise, other radiations, conflicts, and stress, increase the risk to come down
with microwave syndrome.
Active Ingredients and Medications: stimulants, e.g. caffeine, can increase electromagnetic
sensitivity.
9. What Good Are Short-Term Research Projects?
The research projects of today's cell phone, microwave, and telecommunication industry run
for at most one year, very rarely two years. According to the state of knowledge shown, no
harmful effect of the high-frequency electromagnetic radiation can be established at alL. How the factor of
the duration of influence is handled in these research projects should be
explained with an example of a BUWAL study (BUWAL = Switzerland's Department of the
Environment). The findings of a table of scientific works regarding the investigation of the duration of effect
of high-frequency microwave radiations on various function systems or states of health, which one of us
extracted and compiled from the tables of the BUWAL document, shows that among 129 analyzed scientific
works or studies, an immediate effect (up to 1 h) was investigated in 44% of them. The duration of effect
was tested for the short-term (up to three days) in 22.5% of them and for the middle-term (3-30 days) in
11 % of them. Only 22.5% investigated the duration of effect of high-frequency microwaves longer than a
month.
It must be added that cardiovascular, hormone system, and immune system symptoms of
radio-wave or microwave sickness are cited in the BUWAL documentation in the form of
headaches, sleep disorders, general condition, EEG changes, and information processing,
which the authors could not explain with their one-sided conceptions of the thermal effects of
high-frequency electromagnetic radiation.
With such erroneous research approaches, of course no health-damaging effect can be found.
Such research projects are also completely unnecessary, because the athermal, healthdamaging
effect of high-frequency electromagnetic radiation has been known for 75 years and
has been confirmed again and again during this time in more than a thousand investigations,
whenever serious principles of research were guaranteed.
10. The Following Definitions Are Cited For Better Understanding of the Effect of High-Frequency
Electromagnetic Radiation on People and
Corresponding Interpretations
10.1 Health Definitions
Various views have existed about the term "health" for 60 years. Conventional medicine defines health as
the exemption from organic, verifiable sicknesses.
Such a definition does not correspond to the realities. The so-called "functional syndrome" or
somatoform disorders (ICD 10F) are not accounted for in it. In the founding preamble of WHO, health is
defined as follows: "Health is the condition of the complete physical, mental, and social well-being and not
the exemption from
9/13/2010
.5~
sicknesses and ailments." In the O. ia Charter of 1986, this definition \i extended as
follows: Health is to be understood "as a satisfactory measure of functional capability in
physical, mental, social, and economic regards and the ability to take care of oneself
until an old age" (WHO 1987).
10.2 Bioactive Effect and Health Damage
The terms health damage, bioactive effect, or bioactive reaction are frequently used without
being sharply delimited from one another, thus leading to confusion. Therefore, a short
definition for clarification: A bioactive effect is mostly an unspecific reaction of the organism to outside
influences of
various natures (physical, chemical, social, bacterial, viral). It must be differentiated:
? if this reaction is temporary and the homeostasis (norm) recuperates through a
reversible transient effect; that is an individual's normal adaptation reaction, or
? if the changed reaction remained temporarily (e.g. several days) and then "normalized"
again through a reversible transient effect. That would be equivalent to a health
disorder in which the foreign influence was effective as a trigger, or
? if the triggered changed reaction involves problems, losses of abilities to do things, and
quality of life for the long-term and is not reversible. That is damage to one's health.
Under health damage, we thus understand enduring or intermittent irreversible changes of the
physical, mental, and social functional capability of the person, which can arise from noxious influence
developed over the short-term or long-term, or also from intense, short-term.
influences (e.g. shock). (Noxa = pollutants, harmful agents, pathogenic causes)
11 . Animals and Plants are Also in Danger
Animals and plants are also very negatively influenced by this high-frequency electromagnetic radiation. In
the case of cows, reduction of the milk yield and malformed
offspring have been proven. Graver for humankind could be the death of bees observed everyhere due to
the electro-smog contaminated environment. When the bees are dead, people not only have no more
honey, but also no more fruit, because pollination of the flowers is impossible without bees. Humankind
stands today before an important decision: further development of the technogenic pollution of the
environment or finding our way back
to Nature.
Let us remember the report of the Club of Rome (1983) in which there is the following
statement: "The pressure of the facts is so great that we must either change our way-of-life or disappear
from the face of the Earth."
Literature
The literature can be requested from the author or from the internet: ww.hese-projekt.org
5~
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Page 1 of 1
Terry Dorsey
From: Ellen Pirie
Sent: Monday, September 13, 20102:51 PM
To: Terry Dorsey
Subject: FW: Smart Meters
-----Original Message----From: leonard (mailto:[email protected])
sent: Monday, September 13, 2010 2:39 PM
To: John Leopold; Ellen Pirie; Neal Coonert; Tony Campos; Mark Stone
Subject: Smart Meters
Greetings County Board of Supervisors,
I would like to express my opposition to installing wireless Smart meters on our gas and electric meters. These wireless
mesh networks are proven to be unhealthy due to radiation exposure. There is much evidence showing that exposure to
high frequency radio waves is harmful, but it seems PGand E and the CPUC and other authorities have chosen to
ignore or downplay these facts.
I would like to point out that Smar meters can and have been implemented using the existing power lines as carriers of
data. This is called PLC or power line carrier transmission and has been implemented in Europe extensively. A San
Jose CA company known as Echelon has implemented this technology that serves up to 26 milion European
customers. (Please see smart meters at Wikipedia for more details). It doesn't use radio waves and thus is safer. Gas
meters are not connected to the power lines of course, but they could be read manually as they are now. There is no
capacity concern with our gas system that I know of, (the San Bruno disaster notwithstanding) so why do we need
smart meters on gas meters anyway? The entire issue of the smart grid has to do with our aging infrastructure in this
country, why not fix that instead of trying to put a band-aid on the problem?
The contractor that is doing the installations locally is called Wellington, and their website claims they are experts in
PLC technology as well as wireless. So there is a choice.
In summary Smart meters can be implemented on our electric lines using the existing lines as carriers and not using
radio waves.
I ask you to do all you can to block this implementation of radio frequency radiation in our county.
Thank you,
Leonard Rimicci,
Santa Cruz CA.
6d9/14/2010
LIST OF CALLERS REGARDING ITEM 52
SEPTEMBER 14, 2010, BOARD OF SUPERVISORS AGENDA
Name: Rhonda Hoefs
P.O. Box 2744
Aptos, CA 95001
Comment: Pass an injunction on installation of Smart Meters.
Name: Jean Pirano
P.O. Box 856
Freedom, CA 95019
Comment: I am against PG&E Smart Meters.
Name: Teri Tickle
612 Frederick Street
Comment: The negative healths effects caused by dirty radiation
are bad for human beings. The installation of PG&E
Smart Meters adds to the radiation pollution.
Name: Judi Grunstra
220 McMillan
Comment: I am against Smart Meters. Please stop PG&E from
installing any more of them in our county.
Name: Michele Anderson
612 14th Avenue
Comment: Please- -no Smart Meters.
Name: Laura Tucker
930 Rosedale Avenue, #39
Capitola, CA 95010
Comment: Hope you can extend the time period to halt Smart
Meters.
Name: Elizabeth A. Walker-Goldkuhl
13334 Highway 9
Boulder Creek, CA 95006
Comment: Thank you for considering action. I urge you to expand
the time period to a full year like the cities of
Fairfax and Watsonville. ~ ~ ~
Page 2
Name: Nicolas Whi tehead
2627 Mattison Lane, Space 1
Comment: I am against Smart Meters. A 3 month ban is
insufficient time. A longer ban period should be put
in place. There are efficiency and medical
issues that need to be studied.
Name: Richard Buckingham
265 Brown Gables Road
Ben Lomond, CA 95005
Comment: Against Smart Meters. PG&E has not given the public
any choice or voice regarding the installation of these
devices.
Name: Davina Baker
750 47th Avenue
Capitola, CA 95010
Comment: Pass an ordinance to expand the ending date from
December to 1 year from date of enactment.
Name: Jennifer Walker
2081 Chanticleer Avenue
Comment: Take action to immediately halt the installation of
Smart Meters.
Name: Sherry Jackson
lives in La Selva Beach, CA 95076
Comment:
More information needs to be gathered re: Smart Meters.
Stop and rethink these Smart Meters.
Look into optic
wiring like in Europe. She posted a do not install
sign on her house and no Smart Meter was installed.
Name: Don Pountain
no address given
Comment: Evidence by PG&E is not correct. Electromagnetic smog
is harmful to human beings.
Name: Gerald Fehr
95 Lily Way
La Selva Beach, CA 95076
Comment: Halt the Smart Meters.
Page 3
Name: Cherie Gronnel
435 13th Avenue
Santa Cruz i CA 95062
Comment: Pass the Smart Meter ordinance to stop installation of
the meters.
Name: Susan Ferrel
217 Claus Court
Aptos i CA 95003
Comment: Moratorium please. I am sensitive to electrical waves.
I don i t want one on my house.
5171C6
F..eedol. Fo..uln
PRESENTS
ARE PG&E fMARTMfTfRf REALLY SMART?
The city councils of Santa Cruz, Scotts Valley, Capitola and Soquel, and the SC
Co. Supervisors have declared a moratorium on the installation of PG&E /tSmart
Meters". Why is PG&E ignoring these explicit demands and going ahead with the
2+ billion dollar /troll out"? The SmartMeter system collects electric and gas usage
from homes and transmits the data via pulsed microwave to a wireless network
(=no meter readers!).
FIND OUT if these microwave meters are the future for GREEN energy or
DANGEROUS and INA CCURA TE and reveal "private details of daily life," ie.:
when people wake up, come home, take a hot bath and go on vacation! Speakers
include:
*Karl Maret, M.D., M.Eng., president Dove Health Alliance, electrical engineer,
biomedical engineer, and MD specializing in Energy and Nutritional Medicine. He has
carried out physiological research near the summit of Mt. Everest, and built instruments
measurements under the Antarctic ice. He knows the science!!
*Dennis Norton, Vice Mayor, Capitola, city council member for 10 years, UCSC grad,
for physiologic
business owner - dennisnortondesigns.com. He has taken a bold stance!
*Joshua Hart, journalist, spearheads campaign to stop PG&E smart meters, see
stopsmartmeters.wordpress.com. 15 year advocate for sensible transportation and public
policy. His Master's thesis- Driven to Excess- on the neighborhood impact of motor
traffic- was covered by over 100 media outlets worldwide. Eloquent and informed!
Wednesday, Sep.15, 2010, 7 pm Live Oak Grange, 1900 17th Ave, Santa Cruz
Guest Speakers - Local Announcements - Open Mic - Free, donations welcome!
Where Ideas Tum Into Acton Every:t Wednesday
"He that 'would make his own liberty secure, must guard even his enemy from oppression;
fòr if he violates this duty, he establishes a precedent that will reach to himself" Thomas
Paine, 1791
Program subject to change See events posted: www.meetup.com/santacruz-freedom forum
Freedom Forum is not endorsed by the Live Oak Grange
ýhl-M-d +n
',+. V" 61q ( I L-! (CJ
.
CBD BOSMAIL
~,,~
~.~
Sent: Monday, September 13, 20109:14 PM
To: CBD BOSMAIL
1
~,
\
)1
Item Number: 52
Name: Barbara Roettger
Address: 329 Rigg ST
Phone: Not Supplied
Comments:
The electromagnetic radiation being put out by the smart meters has got to be considered. I urge you to put
a moratorium on smart meters until PG & E settles it's problems.
9/14/2010
52
CBD BOSMAIL
Sent: Tuesday, September 14, 2010 3:39 AM
To: CBD BOSMAIL
Item Number: 52
Name: Professor Glen Chase
Address: Santa Cruz County
Phone: Not Supplied
Comments:
From: Professor Glen Chase
To: Santa Cruz County Board
of Supervisors
Date: September 14, 2010
Re: So called "Smart Meter" Moratorium Ordinance
Dear Santa Cruz County Supervisors,
i encourage you to pass an ordinance with teeth putting a moratorium on the PG&E so-called "Smart
Meter" Program. I encourage you to make the moratorium a full year, similar to Watsonville. A few-monthsonly moratorium is a blip of time that PG&E is planning on to simply adjust their installation schedule
around Santa Cruz, not handle any of the material objections you've raised, and resume installation in
Santa Cruz County after three months. PG&E has already installed the infrastructure of their "Smart"
program, knowing of a possible short-term ordinance moratorium. A full year ordinance could have a
rescind clause if your concerns are dealt with, so it could end up less than a year if PG&E finally handled
your concerns. Establishing a full year ordinance (even with rescind clause) makes a serious statement,
whereas a 3-month ordinance implies weakness to many.
You Supervisors go to such significant extent to be fair, accurate, reasonable and cost effective all at the
same time while serving the people of Santa Cruz County. PG&E is not like you. PG&E Corporate does not
deal in good faith as you do. You cannot make effective agreements with another party when the other
party violates good faith and integrity. It is like trying to come to agreement with a crack addict, or teach a
pig to sing. It simply can't be done no matter how sincere one party is and how many chances are given to
the other party (PG&E.)
1. The "Independent" investigation of "Smart meter" accuracy is an obvious fraud. The results were set prior
to the investigation. The investigation did NOT sincerely address the claims of tens of thousands of
complaints. It did not follow down the path of those tens of thousands of complaints to identify their true
origin. Rather, it tested in lab conditions not representing the environment or conditions within which the
complaints were made.
It was similar to the example of the new owner of a "Lemon" automobile towing his new car to the
dealership, having the dealership push the vehicle onto the diagnostic analyzer that does not identify that
particular vehicle's problems, and telling the customer that his vehicle checks out fine.
9/14/2010 ~i.
Structure, the company doing the "Independent" investigation is in bed with PG&E. PG&E is a major client
of Structure.
2. The energy-saving advantages of "Smart Meters" that PG&E claims have been disproved by
Economists.
3. PG&E falsely projects the advantages of energy delivery of a Smart Grid as though those advantages
are due to or related to their so-called "Smart Meters." None of the advantages of energy delivery of a
smart Grid come from PG&E WiÎeless "Smart Meters.
Wireless meters create health risks. Wireless meters transmit, receive and repeat 1000's of other's meters
signals. PG&E Wireless meters are deployed to create a three-dimensional mesh network that is attached
to each home and business at its foundation.
4. PG&E Corporate has in the implementation of this program demonstrated their arrogance and nonresponsiveness to the public, to the city councils and boards of supervisors and other elected officials
representing the people.
Only after ordinances are about to be passed does PG&E Corporate finally send representatives. Yet these
representatives have little information, no authority and are only serving PG&E's desires to stall and slow
down any action against PG&E.
This devious management strategy allows PG&E to secure a greater foothold with these meters and their
infrastructure. PG&E corporate knows that it wil be more difficult to have meters and infrastructure
removed than to stop their installation.
5. PG&E has been cutting service to ratepayers for some time now to improve their bottom line and
increase the $ multi-million dollar bonuses to PG&E corporate execs.
6. PG&E has been using funds from ratepayers designated for service and maintenance to instead improve
salaries and bonuses for Corporate Executives.
7. Please don't forget that PG&E's lack of customer response has lead to disaster with people dying in San
Bruno from explosion and fire.
8. Please don't forget that PG&E is responsible for parents, children and entire families taking ill and dying,
as documented in the Erin Brockovich Movie.
9. Please don't forget that PG&E colluded with Enron during a recent energy crisis.
10. Please don't forget that PG&E placed their Money and assets in a holding company and then went
broke, leaving California Tax Payers to foot the bill for PG&E's bankruptcy and irresponsible behavior.
Please pass an ordinance with at least a one-year term and strong measures of enforcement.
Thank you,
Professor Glen Chase,
[email protected]
91l41.!).
CBD BOSMAIL
Sent: Tuesday, September 14,20105:30 AM
To: CBO BOSMAIL
Item Number: 52
Name: Randy S. Baker MD
Address: 2955 Park Ave.
Phone: 831 476-1886
Soquel, CA 95073
Comments:
Dear County Supervisors,
I am a Family Physician who lives in Soquel, where I have practiced for over 22 years. I am extremely
concerned about the serious potential health hazards associated with the installation of PG & E "Smart
Meters" and strongly urge you to vote YES on the proposed moratorium for installation of such meters in
Santa Cruz county. PG & E's assertion that these meters pose no health hazard is not supported by a very
large body of scientific research on the effects of RF radiation. There are absolutely no studies specifically
demonstrating that these meters are safe, and there are many people who are reporting serious adverse
consequences from exposure to meters already installed (you can read some of these reports here:
http:// emfsafetynetwork. 0 rg/?page _id=2292).
While some of the symptoms may be related to anxiety caused by fears of adverse effects from these
meters, many people developed symptoms before they were aware that the meters had been installed. It is
far too risky to expose our entire population to the potential hazards such as increased risk of cancer from
"Smart Meters" until there is solid research demonstrating their safety.
An excellent summary of the scientific case for the potential for serious
health hazards can be found here:
http://ww.electricalpollution.com/smartmeters.html
(some of this is an addendum at the end of this letter in case you receive this in a written form that does not
allow you to click the link)
Another reason to oppose these meters is elucidated by
Lawrence Bragman, Vice Mayor of Fairfax, a Marin town which has banned the meters, "This is not a
democratically deployed system. It is being forced upon us by a series of undemocratic decision-makers.
And the trustees of the information collected will be a series of corporations."
The following local governments have demanded a halt to the
smart meter program:
City and County of San Francisco, Santa Cruz and Marin Counties, and the cities of Sebastopol, Berkeley,
Cotati, Fairfax, Santa Cruz, Piedmont, Scotts Valley, Capitola, Watsonvile, Sausalito, Belvedere, Monte
Sereno, Novato, Richmond, Ross, Bolinas, and Camp Meeker.
9/14/2010 ,;
I hope that the Santa Cruz County Board of Supervisors will continue to be part of this coalition of
communities in their efforts to protect the health of their citizens. .5 ~
Sincerely,
Randy S. Baker MD
Attached excerpt from http://ww.electricalpollution.com/smartmeters.html:
Transmitting smart meters are being installed nationwide on gas, water, and electrical services, driven in
part by funding for the Smart Grid Program approved as part of the American Recovery and Reinvestment
Act of 2009.
This is of great concern because the exposure to microwave and radiowave radiation from these meters is
involuntary and continuous. The transmitting meters do comply with Federal Communications Commission
(FCC) "safety" standards. However, those standards were initially designed to protect an average male
from tissue heating (cooking) during a brief exposure. These standards were not designed to protect a
diverse population from the non-thermal effects of continuous exposure to microwave and radiowave
radiation. Therefore, these "safety" standards were not designed to protect the public from health problems
under the circumstances which the meters are being used. The transmitting meters most often being used
transmit continuously, every few seconds. This is picked up by a receiver and logged by the utility. You are
exposed to the transmissions from all the meters within transmitting range. The meters often have a range
of over 2 miles. Thus, the exposure is continuous and the "safety" standards the meters comply with are
irrelevant to the situation. Please read this letter from the Radiation Protection Division of the Environmental
Protection Agency (EPA) regarding the limitations of the FCC standards.
Some transmitting meters transmit at less frequent intervals, however, they still seem to be causing health
problems. This could be due to the still elevated levels of radiowaves and microwaves in the neighborhood
because of all the neighbors transmitters. Remember, many, many meters are transmitting at these
intervals. (One person with a meter transmitting hourly reports waking at the time it transmits.)
The transmitting meters can also put high frequencies directly on home and building wiring. This can
happen deliberately through signaling to electrical loads or inadvertently through poor engineering. Poorly
engineered meters can cause electrical pollution by putting the transmitted signal directly on home wiring or
by the way they draw power to operate. Whether deliberate or inadvertent, studies are finding high
frequencies on building wiring is related to a host of health problems. Milham and Morgan found a doseresponse relationship between high frequencies present on building wiring and cancer. Removing high
frequencies on building wiring has improved MS symptoms, blood sugar levels, asthma, sleep quality,
teacher health, headaches, ADD, and numerous other health problems. (Visit Research page to see
papers.) Technical papers provide a solid electrical and biomolecular basis for these effects. A recent paper
by Ozen, showed that transients induce much stronger current density levels in the human body than does
the powerline 60Hz signaL. A technical paper by Vignati and Giuliani discusses the authors' findings that
high frequency communication signals on power lines also induce much stronger electrical currents in the
human body than a low frequency signal of the same strength. The induced currents disturb normal
intercellular communications. This causes harmful short-term and long-term effects. Please see the
Technical page for information about properly measuring the high frequencies on building wiring that are
causing health problems. There is also a simple meter that lay people can use to easily measure most high
frequencies on building wiring.
The objectives of the Smart Grid Program can be accomplished without transmitting meters and without
using other technology such as high frequency communication over power lines, which are also harmful to
human health. It simply requires that meters be selected that are properly engineered to meet the needs of
the program without using dangerous technology. Multi-rate billing and other sophisticated metering options
do not require that the meter transmit. Models are available that download periodically on phone lines,
dedicated communication lines, or are read by a reader the meter reader carries. Dedicated communication
cables can be used to shut off or allow on certain power consuming electronics such as air conditioners. It
is essential that only meters that do not transmit or put high frequency signals on building wiring are
9/14/2010 5::
approved for the Smart Grid Progn.
Tlie un-safeness of the "safety" standards for the continuously transmitting smart meters is apparent from
the reports of health problems ranging from headaches to poor sleep to heart palpitations that begin after
their installation.
Transmitted microwave and radiowave radiation also have the potential for causing serious long-term
health consequences, even for those who do not notice overt symptoms. The majority of independent
studies report similar results: impairment of cellular communication, DNA breakages, increased stress
proteins, etc. Studies targeting cell
phone and cordless phone usage are finding increased risk of brain
tumors. Children seem to be particularly vulnerable. A review of studies performed prior to 2007 is available
at http://ww.bioinitiative.org. A recent public health study provides particularly strong evidence that we
should be concerned about continuous exposure to transmitted microwave radiation. It can be found in a
paper published in Pathophysiology (Volume 16, Issue 1, June 2009, Pages 43-46) Apparent decreases in
Swedish public health indicators after 1997-Are they due to improved diagnostics or to environmental
factors? The authors looked at trend lines in data collected by the Swedish government and found that the
introduction of cellphone technology nationwide in 1997 coincided with the beginning of an accelerating
deterioration of several health indicators. Specifically, the rates of prostate cancer, brain tumors,
melanomas and lung cancers in the elderly all increased dramatically. So did deaths from Alzheimer's
disease, traffic accident injuries, sick leave rates, and percentage of infants born with heart problems. This
paper is short and well worth reading. We should resolve the public health questions before introducing
further public exposure to microwave radiation, particularly involuntary continuous exposure.
Radiowave and microwave radiation are not just a problem for people, they are causing serious problems
for animals of all types. Please visit http://ww.hese-project.org/hese-uk/en/issues/emr.php?id=bees and
http://ww.hese-project.org/hese-uk/enlissues/ for more information.
9/14/2010
5'1

Item #52

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