For the Record...

This is my rebuttal to DTE Energy Vice Chairman, Steve Kurmas, who gave his verbal testimony to the Michigan Energy Policy Committee on February 21, 2017, regarding "smart" AMI meters.  His verbal testimony starts at about 1:15:00 in the above video.  He also submitted written testimony here.  

Mr. Kurmas wrote that over 65 million AMI (smart/electronic) meters have been installed across the US with no issues of health or security.

Regarding Health...

Of course utility companies are going to tell you that their new equipment is safe.  That is what they have been told by the manufacturers.  The manufacturers claim the equipment is safe because it falls within certain FCC guidelines.  They don't mention that the FCC is not a health regulatory agency, they are not protecting the public's health, and the FCC guidelines have been under attack for a number of years.  

Mr. Kurmas also did not mention that the United States is one of three countries that allows about 100 times more outdoor pulsed radiofrequency radiation than most the rest of the world, and that never before in recorded history have over 2 million transmitting public utility meters been installed in Michigan.  So we, and other states fitted with electronic public utility meters, are literally functioning as test markets on health effects.

Image from the Environmental Health Trust

Mr. Kurmas also did not mention all the people who testified to ill health effects after smart or electronic meter installation, at the 2014 Michigan OversightCommittee Hearing.  

Since then, many more Michigan citizens have come forward, testifying to adverse health effects after electronic meter installation, including myself.

Mr. Kurmas also wrote, "the average cell phone produces as much as 100,000 times more RF than an AMI meter."  What he did not tell you is: That statement has been challenged by a Professor of Nuclear Policy, Daniel Hirsch.  Hirsh states that when corrected for duty-cycle and whole-body exposure, "the cumulative whole body exposure from a Smart Meter at 3 feet appears to be approximately two orders of magnitude higher than that of a cell phone, rather than two orders of magnitude lower." 

As of February of this year, the World Health Organization updated its "Cancer Fact Sheet" page to include non-ionizing radiation as a risk factor under the category "Reducing the Cancer Burden".  Electronic "smart" meters emit pulsed non-ionizing radiation continuously.

Traditional analog meters do not expose us to pulsed non-ionizing radiation, a possible human carcinogen.

Regarding Security...

In March of 2016, Computer Weekly (dot) com posted an article written by Bryan Glick, titled "Government warned of smart meter security threat back in 2012."  The article concludes with a call for the "smart" meter project to be "'halted, altered or scrapped' immediately to avert an expensive IT failure."

Another article, from Security Week (dot) com, written by Eduard Kovacs in January of this year, is titled "Smart Meters Pose Security Risks to Consumers, Utilities..." and begins with, "Serious vulnerabilities in smart electricity meters continue to expose both consumers and electric utilities to cyberattacks."

In his verbal testimony, Mr. Kurmas admitted that the information gathered from a smart meter is akin to the information you would get if you stood in someone's yard right next to their analog gas, electric, and/or water meter.  He did not say that by doing so, you would be able to tell if someone got up in the middle of the night, slept-in, or even if someone was home, late getting home, or on vacation.

Traditional analog public utility meters do not make our homes and our privacy vulnerable.

Regarding Canada...

Mr. Kurmas also stated that in 2012, Canada attained 100% AMI installation.

What Mr. Kurmas did not tell you was that in 2014, SaskPower of Canada pulled 105,000 smart meters after "eight unexplained fires associated with the units."

And, in 2016, Canada had to "pull the plug" on over 36,000 rural smart meters because of signal issues.  At that time, Hydro One of Canada reported that 6% of their one million customers were having billing issues.

Canada's auditor-general stated there are "few benefits for the hefty cost" of smart meters.

In his 14 years of being with the Fire Department, Fire Chief Duane Roddy of Oscoda Township, had never himself witnessed a traditional analog meter fire.  Yet, as he testified in front of you (Michigan's Energy Policy Committee) on February 21st, within 36 hours of installation, the smart meter on his cabin "arced" and almost caught his cabin on fire.  

"Thirty-six hours after installation, I had a fire myself," testified Fire Chief Roddy, 

"we're seeing... the fire is at the meter."  

Was that a blessing of disclosure in disguise?

Availability and maintenance... 

Mr. Kurmas also stated that analog meters were not manufactured any longer.  There are a couple of different websites I know of where anyone can order an analog electric meter.  So they are available.  And if the law of supply and demand is true, the supply will follow the demand.

Mr. Kurmas also stated that traditional analog meters needed to be maintained.  However, he didn't mention that traditional analog meters have a life expectancy of double (or more) that of AMI smart meters.  So they will either be checking traditional analog meters, or totally replacing AMI smart meters, every few years.  Is that more "green", or less?

Links...

• Written Comments on HB 4220 by Steve Kurmas, Vice Chairman of DTE Energy
• About the FCC
• Isn't the FCC protecting us?
• International EMF Scientist Appeal to the World Health Organization
• Michigan Oversight Committee Hearing December 2014 Part 1
• Michigan Oversight Committee Hearing December 2014 Part 2
• Professor Daniel Hirsch Abstract on Smart Meter Health Impacts
• Article:  Government warned of smart meter security threat back in 2012
• Article:  Smart Meters Pose Security Risks to Consumers, Utilities
• Article:  Hydro One pulling plug on 36,000 rural smart meters after years of complaints
• Canada's auditor says "few benefits" from US $1.7bn rollout

New Public Utility Rules - My Comments

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:

• http://www.lansingstatejournal.com/story/news/local/2016/10/12/bwl-employee-severances/91862614/
• https://www.wired.com/2016/03/inside-cunning-unprecedented-hack-ukraines-power-grid/
• http://www.businessinsider.com/power-grid-hacking-ukraine-2016-6
• http://www.makeuseof.com/tag/home-security-systems-may-not-secure-think/

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:

• http://fox17online.com/2016/04/07/business-owner-with-smart-meter-receives-13000-consumers-energy-bill/
• http://fox17online.com/2016/04/08/22000-bill-for-two-bedroom-kalamazoo-home-leaves-owner-in-shock/
• http://tdn.com/news/local/customers-protest-high-electricity-bills-call-for-meter-audit/article_786cd8c0-d432-53e1-bd73-12acd180e234.html
• http://pittsburgh.cbslocal.com/2016/01/05/electric-bill-spikes-blamed-on-smart-meters/
• http://www.kabc.com/2016/03/21/improperly-calibrated-smart-meters-raises-ire-of-city-council-member/
• http://www.reddirtreport.com/red-dirt-news/claremore-smart-meters-create-substantial-increases-bills-residents-claim
• https://envirowatchrangitikei.wordpress.com/2015/08/28/how-smart-meters-are-harmful-raise-costs-and-invade-privacy/

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)