Below (in black) is the comment I submitted to the Michigan Public Service Commission (MPSC) regarding the proposed new public utility rules. The proposed new rules can be viewed here. And comments submitted should be posted for the public to view at their e-Dockets site here.
Someone had discovered that the MPSC was allegedly redacting comments that had to do with health and medical treatment, and suggested the verbiage in the first two paragraphs of my comment.
October 10, 2016
Executive Secretary
Michigan Public Service Commission
P.O. Box 30221
Lansing, Michigan 48909
Re: MPSC Case No. U-18120
Dear Sirs and Madams:
Please
Note: I want the information
below and any attachments published in full in the public comments section of
the edocket for U-18120. Under the First Amendment to the U.S. Constitution, I,
as a private person, have every right to disclose and disseminate, in whatever
form I choose, any information about myself, including information about my
health and health reports from medical professionals. There is nothing in the
Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) that precludes
me from doing so.
The Commission does not fall under HIPAA rules and may not
use the language of HIPAA to circumscribe the commentary I wish to make of my
own free will on the public record in this or any other proceeding in regard to
my health or in providing documents from an entity covered by HIPAA. The Commission is not a health plan, health
care clearinghouse, or health care provider, nor does it perform functions or
services on behalf of a an entity covered under HIPAA. HIPAA applies only
to "health plans, health care clearinghouses, and to any health care
provider who transmits health information in electronic form in connection with
transactions for which the Secretary of HHS has adopted standards under
HIPAA." See HHS.gov at
https://www.hhs.gov/hipaa/for-professionals/privacy/laws-regulations/. The only
other type of entity that might be governed by HIPAA "is a
person or organization, other than a member of a covered entity's workforce,
that performs certain functions or activities on behalf of, or provides certain
services to, a covered entity that involve the use or disclosure of
individually identifiable health information. Business associate functions or
activities on behalf of a covered entity include claims processing, data analysis,
utilization review, and billing.” Id.
In reviewing the proposed new
rules, I have found areas of concern I will describe, along with my questions:
R 460.102 Definitions; A to F. (b) talks about customer account information and
data. The words "extraordinary effort" are
used. This is vague. One person's extraordinary effort is
effortless for another, such as a hacker.
With smart metering
technology, cyber security is a real threat.
Did you know that Lansing's Board of Water & Light
got hacked into this past April? Or that
hackers have already taken down the power grid in the Ukraine? What is being done to address these real
threats to our *safety? (*See end note)
Please see the following links
about smart meters and hacking:
R 460.111 General deposit conditions for residential customers. (8) This is the first place in
the proposed new rules where utility companies want to REDUCE the amount they
pay to customers in interest by 2%. Why
would you allow this? Are utility
companies loosing money? Is this
*reasonable?
R 460.111a
General deposit conditions for nonresidential customers. (5) Another mention of reducing interest utility companies
pay to customers on deposits, from 7% to 5%.
While utility rates and tariffs continue to rise, utility companies
charge customers more, but PAY customers less when they hold customer money. I do not consider this *reasonable. Do you?
R 460.116 Meter relocation.
Rule 16. (1) (b) This rule addresses if
a customer threatens harm to a utility worker.
What about utility meters that harm customers? Are you not a "Public Service Commission"? I thought you were supposed to help protect
public utility customers by promoting *safe service. If that it not your job (among other things)
to help protect public utility customers, then what IS your job?
R 460.126a
Billing error. Rule 26a. (1) This rule proposes
another reduction in the interest utility companies pay customers, from 7% to
5% on overcharges. Again, is this
*reasonable? Or is this benefiting the
utility companies at the EXPENSE of the customers?
This rule also states: "A utility is not required to adjust, refund, or credit an
overcharge plus 5% (which should remain at 7%) APR interest for more than the 3 years immediately preceding discovery
of the billing error..." This
is unacceptable! New NON-ANALOG public
utility meters have a history of overcharging.
This proposed rule would relieve public utility companies of some of their
responsibility for choosing to install faulty, inferior equipment and/or for installing
equipment incorrectly.
To relieve utility companies of some of their financial
responsibility to customers is *unreasonable.
Again, it is protecting utility companies at the EXPENSE of the
customers.
Utility
companies must be held accountable for billing errors for no less than 7
(seven) years from the time the error is discovered and pay a minimum of 7% interest on the amount overcharged.
Please see the following links about smart meters and
over-charging:
Did you know that "smart" and digital
"opt-out" electric meters TAKE electricity to run? ANALOG meters do not. Who is paying for this extra electricity usage
to run new electric meters? The customer
is. Is this additional financial burden
to customers *reasonable?
R 460.137
Shutoff or denial of service permitted. (1)
Why is the word "hazardous" used
here but NOT defined under R 460.102
Definitions? This word and this
statement are both too vague for a document of this magnitude. This is definitely NOT a *reasonable rule.
R 460.137 (1) would allow
utility companies to shut-off service to customers who refuse the installation
of a new, NON-ANALOG, utility meter. Some
customers already know they are sensitive to new metering technology and
want to keep ANALOG meters.
If our natural gas provider
had told us their new AMR ERT NON-ANALOG meters send signals over 450,000 times
per month, we would have refused installation.
That could happen to a customer in the middle of the winter. It could be just a matter of hours before
water pipes begin to freeze and burst, creating possible catastrophic property
loss for utility customers. Is it
*reasonable to expect customers to accept new metering technology when they are
already aware of a sensitivity to it? Is
it *reasonable to expect customers to be OKAY with natural gas (or electric)
shut-off in the middle of the winter with NO NOTICE?
By not defining
"hazardous," you give utility companies the power to create their own
rules regarding shutoffs as they go along.
This is definitely NOT *reasonable, and makes the Michigan Public
Service Commission of NO VALUE to utility customers.
"Hazardous" must be
clearly defined, please. THAT is only
*reasonable!
Furthermore, the following rules must be added:
(1) Utility companies must provide full
disclosure of what exactly they are installing on customers homes. Utility
companies must provide complete and accurate information about equipment before
installing new equipment.
I was already avoiding cell phones because of a known
sensitivity to radio frequency radiation, prior to new AMR ERT gas meters being
installed.
The gas company told us their new meters only transmit once per month, for the meter read. What they didn't say was that they send
signals over 450,000 times per month. Had they told us the whole truth about their new meters, we would have refused
installation. But we didn't, and within
three months, I started having symptoms of electromagnetic
hypersensitivity. I didn't know it, at
the time. I had no idea the new AMR ERT gas
meters were going to eventually make me extremely unwell.
About a week after I requested information on their new
AMR ERT gas meters, Dave Williams, the Regional Operations Manager at SEMCO Energy,
emailed me with the data about what exactly the new AMR ERT gas meters do. I'm not sure he even knew the details about
their new AMR ERT meters before I inquired.
Mr. Williams also told us they have no opt-out, so the only thing we could do if we wanted the new AMR
ERT gas meters that made me extremely unwell removed, is disconnect natural gas
service. Is THAT *reasonable?
(2) Utility companies must offer an ANALOG
utility meter choice.
There's a growing number of people in Michigan
discovering they are electro-sensitive, thanks to smart meters, as you may
already know, given the number of complaints you have and are receiving. This is a growing health crisis. Please do your job to help protect us. We must be accounted for.
Harm done by wireless technology and electromagnetic
fields has been known about since the 1980's.
Perhaps even before that. You
must do your job and protect the people in Michigan who are electro-sensitive.
Also, new NON-ANALOG electric meters now have a growing
history of explosions and/or starting fires.
Utility customers who wish to AVOID the increased risk of fire from a
public utility meter must be given an ANALOG utility meter choice.
(3) Utility customers must be given the
choice to either:
a. read their ANALOG meter
themselves at NO additional charge if they submit their reading electronically,
or
b. read their ANALOG meter
themselves at NO additional charge save postage if they submit their reading
via the United States Postal
Service, or
c. have the utility company come out
and read their meter for a minimal charge.
(4) Utility companies must be prohibited
from charging customers for utility bills that are printed and mailed via the United States Postal
Service.
This is *reasonable given the fact that not all utility
customers own a home computer. It's
*unreasonable to expect customers to leave their homes in order to view their
utility bills.
I've been told to be respectful to the Michigan Public
Service Commission, however I find it difficult to be respectful to people who
have been defending and protecting those who've taken away my Rights as a Human
Being to *Safety, Security, and Privacy in my own home.
Please, do your job and earn the respect the Michigan
Public Service Commission deserves.
Otherwise, you are a useless organization to the People of Michigan.
Most Sincerely,
Jeanine S. Deal
*R 460.101
Applicability; purpose. (2) These rules are intended to promote safe and adequate service to the
public and to provide standards for uniform and reasonable
practices by electric and natural gas utilities in dealing with residential and
non residential customers. (My highlights added)
