MA Smart Meter Bill Testimony: International Metering Policies & EHS Court Cases, Cost Disparities
Please feel free to share with others served by Eversource and National Grid, and anyone else interested!
I prefer to be behind the scenes, (and grateful that other advocates are comfortable in the spotlight)…but a number of individuals have asked me to post my recent smart meter bill testimony. For those that watched the video, the Committee Chair thanked me for my “interesting testimony” and asked me to provide references/sources…(which I would do anyways). (You can judge for yourself if he was casting doubt/throwing shade.)
While the MA legislature meanders through its 2-year session, new digital meters are already being quietly installed. (See; Only 21 of 10,500 bills passed by MA Legislature In September of 2024, in an editorial for CommonWealth Beacon, Pittsfield MA resident Jeanne Kempthorne asked, Why can't the Legislature do its job? “The Massachusetts Legislature is one of the least effective, least efficient, and least transparent legislatures in the nation.”)
There were significant technical difficulties during the smart meter bills hearing, with testifiers not able to be admitted when their name was called, and the audio blanking out between speakers so those on the phone couldn’t hear their names being called, nor could they hear the timer buzzer. Because of a time-delay between the video stream and the actual event, speakers calling in had no idea how long they actually spoke. and some ran over most likely inadvertently, (including me, and Kirstin of Last Tree Laws)
When I saw this article today; Major Gov’t Agency Cuts Ties With Microsoft After Teams and Windows Failures I was not surprised.
Other testifiers spoke on other smart meter topics, including the science, and the human rights issues.
I focused on the utilities hiring product defense teams, EHS court cases in other countries (being referenced as EMR-S in the US), international smart meter rulings re EHS, Germany’s Intelligent Metering including not installing transmitting meters on low usage homes with no load to shift, Vince Welage’s investigation of cost disparities in Ohio, and the Worcester smart meter pilot debacle. (Most MA residents have no knowledge about this.)
I also documented that the differences in opt out fees being charged make no sense and are not cost based. I provided additional documentation outlining issues with the AMR opt-out already in place in MA, which is listed after the footnotes for the first written submission.
I am so grateful for the international support, including Europeans for Safe Connections, and the report “History of the discussion on radiation exposure by digital meters in Flanders and arguments against the 'wired' meter with 4G outdoor antenna” provided by Beperk de Straling, PHIRE, the work of the Ohio groups including Vince and Monique, the California activists, especially Sandi Maurer of the EMF Safety Network, the Worcester Community, and our colleagues across MA.
I received more smart meter information from other countries after I submitted my testimony, and I will share them in another article soon.
Oral Testimony in Favor of Bills Senate.2306 An Act relative to smart meters and House.3551 An Act relative to smart meters - (3-minute limit for oral testimony)
To: Massachusetts Legislature’s Joint Committee on Telecommunications, Utilities, and Energy From: Patricia Burke Date: June 12, 2025 Oral Testimony
I am Patricia Burke, from Millis. I work with Safe Tech International.
In most jurisdictions, smart meters become an issue after meters are installed and harm occurs. But no injury data has been collected.
Yet 15 years ago, emails released following the San Bruno gas explosion in 2010 showed that the industry already knew that injury was occurring.
But consulting firms Navigant and Structure were hired to bury emerging issues.
Navigant also buried unfavorable results for the Worcester National Grid smart meter pilot.
And the 2021 court ruling in the US questioning adequacy of FCC exposure guidelines has been ignored.
EHS court cases have been won in the UK, Australia, Spain, Netherlands, and France.
In Brussels and Wallonia, the Constitutional Court ruled that a radiation-free meter must be available for people with EHS. The Netherlands, Australia, Belgium, and Norway have had non-transmitting meter options for many years.
France recently required the removal of Linky smart meters due to EHS.
Germany has taken the lead in intelligent metering, and is not installing transmitting modules on households consuming less than 6000 kilowatt hours per year, greatly decreasing ambient exposures and costs.
Vince Welage determined that low usage consumers in Ohio are actually subsidizing higher energy users through the high percentage of fixed charges, especially with opt out customers who are paying twice, for the punitive surcharge and the infrastructure that is of no benefit to them.
Opt out fees for MA create another cost disparity, and make no sense. National Grid’s opt out fee in NY for both electric and gas is a total of $17.71 for both.
In MA the opt out fee for only the electric meter is $26.00/month, and historically, NGrid only read the meters every other month. During covid, the meters were never read, but customers were still charged the opt out fee.
Eversource’s fee is a more punitive $34/month., over $400/year.
These are not cost-based fees, (not based on truck rolls and labor.)
In Germany, low usage customers read their own meter.
Advocacy for a proactive bill has been presented to the MA Legislature for over a decade.
Now that 2.9M meters are being installed, there is an emergency preamble, caused in great part because the DPU promoted the testimony of a mercenary tobacco scientist to override health concerns and risk in 2014. (Peter Valberg of Gradient)
Because the DPU and FCC did not protect the safety of MA ratepayers through reasoned investigation, the Legislature can prevent further harm, and the real probability of stranded assets. Please advance the smart meter bills.
Written Referenced/Footnoted Testimony Re: Please Support the Bills Senate 2306 An Act relative to smart meters and House 3551 An Act relative to smart meters
I am Patricia Burke, from Millis, and I work with Safe Tech International.
I am asking the Legislature to support Senate.2306 and House 3551 regarding smart meters.
Advocacy for utility meter choice and a no-fee opt out bill has been presented to the MA Legislature for over a decade.
Now that investor owned utilities are deploying over 2.9 million meters in the Commonwealth, the bills hold an emergency preamble.
He who controls the data controls the narrative, and we are flying blind regarding the history of over 15 years of smart meter harm.[1]
California
Emails released to the public following the 2010 San Bruno gas explosion reveal that fifteen years ago, California Public Utilities Commission president Michael Peevey knew that smart meters were inflicting harm. [2]
Instead of investigating the fact that the meters posed a health risk to a portion of the population, utilities in Texas and California hired consulting firms Structure and Navigant to bury the emerging problems [3]
We have no data regarding the history of smart meters health damages over the last 15 years.
Rather than investigating the entire smart meter paradigm, the question of health harm was reduced to the battle for opt out provisions, (even though accommodation is generally not even possible in multi-family or densified housing, and the metering creates a much larger access barrier for those who experience electrical poisoning)
Massachusetts DPU
The Massachusetts Dept. of Public Utilities published its 2014 order nullifying risk and reported harm based on testimony from a notorious mercenary health expert[4] also working at the time for Philip Morris cigarettes.[5]
Massachusetts DPU order 12-76-B grossly misrepresented the scope of FCC standards regarding the non-thermal effects of non-ionizing radiation, indicating either possible malfeasance or incompetence.
In MA DPU 20-69 environmental health expert Beatrice Golomb MD PHD provided expert health testimony to the MA DPU clarifying that the installation of a smart meter was the single most common trigger for the onset of intolerance to electromagnetic fields.
Worcester
National Grid also hired Navigant to spin the results of the Worcester Smart meter pilot program, failing to accurately report the opt out statistics for informed customers concerned about health, privacy, security, green-washing, fires, and other risks (about 1/3 of attempted installations enrollments were rejected), in addition to favorably/inaccurately presenting cost savings, energy savings, participation, and customer satisfaction rates.
The Navigant report may meet the definition of financial fraud.
United States and Canada Opt Out Attempts are Representative of Harm: National Conference of State Legislatures
The National Conference of State Legislatures published a summary of state opt out fees in 2019, stating:
“But as utilities increasingly deploy smart meters, a small number of groups oppose their installation, citing a variety of health and privacy concerns about the new technology. This opposition has led at least seven states to enact policies to allow customers to opt-out of having a smart meter installed on their home, while New Hampshire requires customer consent for smart meter installation and Pennsylvania law prohibits opt-outs. In another 22 states, utility regulators have ruled on whether utilities can implement opt-out programs on a case by case basis.”
Every opt out proceeding across the country occurred in part because some portion of ratepayers were harmed, and attempting to protect their health.
A volunteer in Canada has maintained a more accurate list of the many opt out fees In Canada and the U.S. at Citizens for Safer Tech:
https://citizensforsafertech.ca/metersgrid/smart-meter-opt-out-options-and-fees/
In 2012, National Conference of State Legislatures Also Promoted Tobacco Health Experts from Product Defense Firms Gradient and Exponent
Link is no longer available at the NCSL site
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International: Smart Meter Policies and Disability Decisions
Internationally, France has required that the Linky meter be removed from the homes of sensitized individuals. [6]
In Brussels and Wallonia, the issue of the digital meter was brought before the Constitutional Court and the Court ruled that a radiation-free alternative must be available, in particular for people with electrohypersensitivity. In the Netherlands, Australia, Belgium, and Norway meters with the wireless communication module turned off have been offered as an alternative for many years.[7]
(There have also been other legal rulings regarding EMR-S, or EHS, including in the UK, requiring accommodation for a school child,[8] and also a retirement allowance for ill health [9] )
See an international list maintained by Europeans for Safe Connections here: Legal Cases[10]
Germany: No Transmitters on Homes with Low Consumption and No Load to Shed, Only an Energy Monitor for the Consumer
But in particular, I would like to mention Germany’s metering policy.
Germany is providing a home energy monitor, but not a transmitting module, on the homes of low usage consumers, recognizing that these customers do not have reasonable load to shed, and that the costs of installing meters on homes with low usage are not justified, nor should behaviours be expected to change for essential needs.
From Germany: Who gets a digital electricity meter?
“In the coming years, every household will be obliged to change its electricity meter. Households with an average consumption of less than 6000 kilowatt hours per year will receive a digital electricity meter by 2032.
What is the difference between digital electricity meters and smart meters?
A smart meter or intelligent measuring system (iMS) is more than a digital electricity meter, because it includes a modern metering device (mME) and a smart meter gateway (SMGW). For the sake of simplicity, LichtBlick uses the term smart meter in this guide for intelligent metering systems.
Digital electricity meters record electricity consumption in detail
A digital electricity meter measures the consumption in your household and breaks down the data in detail. A display classic households with average consumption, these meters are sufficient.
A digital electricity meter measures the consumption in your household and breaks down the daily meter reading and the corresponding output. A display replaces the classic counting disc. The digital meter can neither receive data from the outside nor pass on information to third parties. You still have to read your electricity consumption manually. For households with average consumption, these meters are sufficient.
Which households will get a smart meter?
Anyone who has an above-average electricity consumption of 6000 kilowatt hours or more per year will receive a smart meter. Such high electricity consumption arises, for example, if there is an electric car in the household that is charged via a wallbox. Electricity customers who operate a solar system with an output of more than seven kilowatts will also receive the intelligent control system with a communication module. Anyone who operates a controllable night storage heater or a heat pump is still excluded from the smart meter obligation, but can opt for it if they wish. - Digital electricity meters: How to benefit from the installation obligation
Note that the “smart” meters being installed in the US do not offer real time usage data to customers.
Ohio: Billing Disparity for Low Usage Customers Subsidizing Higher Usage Consumers
Volunteer citizen researcher Vince Welage in Ohio has been investigating the economic impact of various fixed charges and riders being added to utility bills that create a disparity for low usage consumers.
Especially when combined with the impact of the punitive smart meter “opt out” charges, the economic impacts are overwhelming for many households. The statistical analysis by Vince indicates that consumers who use less energy are clearly subsidizing heavier users. Fixed charges comprise a much larger portion of the overall bill. [11]
This is especially true for opt out customers who are paying twice, for the punitive surcharge and the infrastructure that is of no benefit to them.
Moving forward, the U.S. could easily make a similar policy decision.
Germany appears to much more sensitized to the issues of surveillance and abuse of state power.
(Vince’s most recent handouts were submitted as an attachment, viewable here: https://safetechinternational.org/wp-content/uploads/2025/06/Utility_Study_Handouts-1.pdf
No Rationale for the Disparity in Opt Out Fees Between New York and Massachusetts (National Grid) and Between Eversource and National Grid
Opt out fees for MA create another cost disparity, and make no sense.
National Grid’s opt out fee in NY for both electric and gas is a total of $17.71 for both.
In MA the opt out fee for only the Ngrid electric meter is $26.00/month, and historically, NGrid only read the meters every other month (per MA DPU Order 13-83). During covid, the meters were never read, but customers were still charged the opt out fee.
Eversource’s fee is even more punitive $34/month., over $400/year.
These are not cost-based fees.
In Germany, low usage customers read their own meter.
The Court Ruling Against the FCC Regarding Adequacy of its Exposure Guidelines:
This 25-page testimony was provided to the MA DPU in regard to the Circuit court ruling about the FCC’s exposure guidelines.
https://fileservice.eea.comacloud.net/FileService.Api/file/FileRoom/13950051
Health, Safety, Environmental and Economic Risks, Testimony of Patricia Burke et. al. for MA DPU Dockets 21-90, 21-91, 21-92 Respectfully submitted, Patricia Burke
This testimony addresses the opportunity and urgency for the Massachusetts Dept. of Public Utilities, environmental groups, utilities, and industry to recognize and act prudently regarding recent legal developments concerning Federal Communications Commission (FCC) radio frequency exposure guidelines. Regarding EVs, this pertains directly to ideas about time-of-use billing and off-peak charging via smart meters. Safety questions raised by the court’s August 13, 2021 ruling against the FCC pertain directly to impending decisions and proceedings by the MA DPU regarding wireless smart utility meters, mesh networks, powerline communications, and other grid infrastructure investments, including EV charging. The MA DPU is in a position to adjust grid modernization strategic planning, to reflect necessary recognition that the health and safety assumptions driving pending grid policy and investment decisions, sourced back to 2014, are based on FCC guidelines that have been determined by the court to be not evidence-based. In addition, in 2014, MA DPU 12-76-B misrepresented FCC exposure limits as protective of both thermal and non-thermal impacts of radio frequency exposures. The MA DPU’s claim is misleading and inaccurate. In 2014, members of the public voiced this concern to the MA DPU. 1 The August 2021 court decision against the FCC correctly identified the scope of FCC limits as excluding non-thermal impacts. The misrepresentation by the MA DPU of the scope of the FCC’s exposure limits regarding non-thermal effects has never been addressed, despite being brought to the agency’s attention in filings by the public, and as outlined in MA-DPU 12-76-B itself, seven years ago. The court further ruled “The factual premise—the non-existence of non-thermal biological effects— underlying the current RF guidelines may no longer be accurate.”
An Inadequate Cost-Benefit Analysis, and Outsourcing/Eternalizing the Costs for Health Damages and Disability to the Social Sector
Because the DPU and FCC did not protect the safety of MA ratepayers through reasoned investigation, the Legislature can prevent further harm, and the real probability of stranded assets.
Please advance the smart meter bills.
Thank you.
NOTE TO READERS: THERE IS A THIRD TESTIMONY ABOUT OPT OUT FEES BELOW THESE FOOTNOTES
[1] The Flying Blind reference also refers to the quote by Ct Senator Blumenthal when he questioned the industry about safety testing for 5G.
“Flying Blind” on the Health Effects of 5G Wireless Technology Confirmed at US Senate Hearing After Senator Blumenthal Questions Industry
[2] The CPUC is responsible for regulating the utilities to ensure safe and reliable utility service. Instead, they partnered with PG&E and marketing companies on a smart meter propaganda campaign. CPUC President Michael Peevey intentionally delayed the legal process for years so PG&E could complete their deployment, despite knowing smart meters were overcharging and harming customers. Thousands of emails between PG&E and the CPUC made public this year, illustrate their collusion and corruption. Together they concocted a punitive pay to opt out program, and ignored substantive complaints. The CPUC must address these issues by holding safety hearings, and restoring analog meters without coercive fees.
READ THE REPORT: http://emfsafetynetwork.org/wp-content/uploads/2015/04/Overview-of-PGECPUC-emails-on-smart-meters.pdf “Pressure over smart meter RF health complaints (headaches, sleep problems, ringing in the ears, heart problems, and more) forced PG&E to allow customers avoid smart meters. Initially PG&E considered offering a no cost phone or fiber line option, but later, in cooperation with CPUC, they concocted a fee for avoiding smart meters. PG&E’s Cherry writes, “I’ve got internal parties on board grudgingly and it might be best to let sleeping dogs lie.”
[3] http://emfsafetynetwork.org/we-agree-with-san-bruno-remove-cpuc-president-peevey/
[4] MA DPU 2014 12-76-B, Peter Valberg of Gradient is not identified by name in the order, nor did he submit written testimony, but he is identified by name in the hearing transcript.
[5]. Phillips vs. Philip Morris Companies
[6] French court orders removal of Linky smart meter from home after health complaints https://smartmeterharm.org/2025/04/26/french-court-orders-removal-of-linky-smart-meter-health-complaints/
[7] https://safetechinternational.org/wp-content/uploads/2025/03/2024-11-30-History-discussion-smart-meter-RF-Flanders.pdf
[8] https://phiremedical.org/education-health-care-plan-ehcp-awarded-aug-2022-for-uk-child-on-the-basis-of-electromagnetic-hypersensitivity-ehs/
[9] https://phiremedical.org/early-ill-health-retirement-and-employment-support-allowance-awarded-on-the-basis-of-electromagnetic-hypersensitivity-ehs-further-detailed-press-release/
[10] International Legal cases include: 2007
Alaska Supreme Court upholds awarding an AT&T equipment installer 100% disability as a result of his workplace electromagnetic field exposure to radiofrequency (RF) radiation at levels slightly above the FCC RF limit;
Australia 2013: Dr. McDonald vs. Comcare, specialist received 75% of salary, unable to work because his employer did not provide protection from radiation even though he was diagnosed with EHS. https://www.austlii.edu.au/cgi-bin/viewdoc/au/cases/cth/aat/2013/105.html
New York 2014: A Manhattan nurse practitioner with a rare brain disorder won a $4 million judgment last week against New York Presbyterian Hospital — seven years after she sued the hospital for forcing her to work in units that exacerbated her painful condition. https://nypost.com/2014/11/23/nurse-with-rare-brain-disorder-wins-4m-suit-against-hospital
France 2015: French court awards woman disability grant for ‘allergy to gadgets’. Court recognises that Marine Richard, 39, suffers from electromagnetic hypersensitivity to everyday devices such as mobile phones. Ms. Richard lives in the mountains of south-west France, in a renovated barn with no electricity, and drinks water from the well. A Toulouse court has ruled that she is entitled to a disability allowance of around 800 euros ($912) a month for three years. https://www.theguardian.com/world/2015/aug/27/french-court-awards-woman-disability-grant-for-allergy-to-gadgets
Spain 2016 A telecommunications engineer who worked for the technology company Ericsson has been declared unfit for work due to electrohypersensitivity, a neurological syndrome that appears when exposed to computers, cell phones, wifi signals or spaces with high electrical and electromagnetic activity. The High Court of Justice (TSJM) of Madrid has recognized his problem, which prevents him from continuing to work without becoming ill, and has ruled that he is entitled to a disability benefit. https://www.heraldo.es/noticias/sociedad/2016/08/02/un-ingeniero-telecomunicaciones-con-electrosensibilidad-logra-incapacidad-laboral-993859-310.html
Italy 2016 The Court of Florence confirmed the link between prolonged mobile phone use and an acoustic nerve tumor in a sales employee who used a phone for 2-3 hours daily over ten years. INAIL was ordered to grant him a disability pension pension of 16%. https://www.dottnet.it/articolo/20746/tumore-da-uso-del-cellulare-altra-condanna-per-l-inail More legal cases at link: https://esc-info.eu/en/legal-cases/
Slovakia 2018 The Main Court confirmed that a citizen has the right to be a participant in construction bureaucratic proceedings if a telecommunications transmitter is being built near him.
[11] https://smartmeterscience.substack.com/p/unconscionable-practices-of-major
Additional Testimony in Favor of Senate 2306 An Act relative to smart meters & House 3551 An Act relative to smart meters: Regarding Opt Out Fees and Practices
To: Massachusetts Legislature’s Joint Committee on Telecommunications, Utilities, and Energy Attn. Chair Senator Barrett From: Patricia Burke Date: June 19, 2025
During my oral testimony on June 12, I spoke about the fact that “current opt out policies proposed for Massachusetts create billing disparities, and also make no sense.”
Senator Barrett requested that I provide documentation.
I have already submitted the links to the varying opt out fees for NGrid in New York vs. Massachusetts in my written hyperlinked testimony.
“ National Grid’s opt out fee in NY for both electric and gas is a total of $17.71 for both.
In MA the opt out fee for only the Ngrid electric meter is $26.00/month, and historically, NGrid only read the meters every other month (per MA DPU Order 13-83). During covid, the meters were never read, but customers were still charged the opt out fee.
Eversource’s fee is even more punitive $34/month., over $400/year.
These are not cost-based fees.”
I am now submitting documentation in support of the comments I made about the meter reads.
The 2013 National Grid AMR Opt Out Proceeding at the MA DPU
In 2013, National Grid was already receiving and granting opt out requests for those customers who did not want to have transmitting digital meters on their premises anymore.
Note that the issue of smart meter health harm was brought to the attention of the public and decision makers when smart meter deployments across the country were associated with symptom onset and disability.
A number of Ngrid customers in Worcester became aware of the smart meters because of the very visible National Grid smart meter pilot and its extensive marketing campaign.
There were 2 classes of customers requesting an opt out in the Commonweatlh – those targeted for the new AMI meters in the National Grid pilot, and those who had an AMR meter and had become aware that it may have been a factor causing harm to health, and/or with a diagnosis of EHS/EMR-S or other neurological or chronic health condition.
Although the public face of National Grid was that they were offering a no-fee opt out from smart meters “due to their commitment to customer choice” for the smart meter pilot, behind the scenes National Grid asked the MA DPU to allow them to surcharge another class of customers, and not to honor a commitment to customer choice for AMR metered customers….and the MA DPU was complicit.
DPU 13-83: On June 5, 2013, over 12 years ago, National Grid petitioned the DPU to impose a surcharge on customers with AMR meters who wanted to address their RF exposure
Description: DPU 13-83 Petition of Massachusetts Electric Company, Nantucket Electric Company, Boston Gas Company and Colonial Gas Company, each d/b/a National Grid, for approval by the Department of Public Utilities of proposed electric and gas tariffs entitled "Residential Automatic Meter Reading Opt-Out Provision".
Here is the hyperlink to the original AMR tariff request.
“Because the AMR technology has been in place for approximately a decade, the Company’s current rate structure reflects the costs of reading meters using AMR technology. Accordingly, the Company is proposing that customers who elect a non-AMR meter be required to bear the additional associated costs under the proposed tariffs in order to offset the increased incremental costs to the Company to manually read the non-AMR meters. In addition, the Company may be unable to read the non-AMR meter every month, based upon the location of the meter, in which case an estimated read will be used.”
Note that there are 52 documents within the docket file, and many of them include early warnings to the Department of Public Utilities about harm to health.
The DPU’s April 30 2014 order by Chair Berwick is here:
The Company proposes to provide an option to its residential electric and gas customers to replace the Company’s AMR meters with non-AMR meters (Exh. NG-PTZ-1, at 3). The D.P.U. 13-83-A Page 5 Company has received 20 requests from residential electric customers and four requests from residential gas customers to have their AMR meters replaced by non-AMR meters (Exh. NG-PTZ-1, at 3-4; Tr. at 84-86). The Company stated that most of these requests resulted from customers’ aversions to RF-emitting devices at their homes (Exh. NG-PTZ-1, at 4). The Company stated that customers of National Grid’s affiliates in New York and Rhode Island have returned meters to those affiliates after the customers had removed their AMR meters themselves and replaced them with non-AMR meters (Exh. NG-PTZ-1, at 4). The Company states that a customer replacing a meter creates significant safety risks both for the customer and for Company employees (Exh. NG-PTZ-1, at 4). National Grid therefore proposes to offer residential customers the choice to opt out of their AMR meters, provided those customers pay the incremental costs associated with this option (Exh. NG-PTZ-1, at 4).
Proposed Residential Electric Opt-Out Tariff The Company’s proposed opt-out tariff for residential electric customers would require customers to pay an installation fee of $26.00, which includes National Grid’s incremental labor costs to remove an existing AMR electric meter and replace it with a non-AMR electric meter (Exh. NG-MJC-1, at 6). Opt-out electric customers’ bills would include an additional $11.00 monthly charge for manually reading a non-AMR electric meter (Exh. NG-MJC-1, at 6). National Grid states that this monthly fee includes the incremental labor costs associated with Company employees’ manually reading the non-AMR electric meter, as compared to costs associated with reading AMR electric meters (Exh. NG-MJC-1, at 6).3 Should an electric 3 The Company performs AMR meter readings by driving vehicles equipped with RF receivers past residences with AMR meters; the vehicles receive an RF signal transmitted by the AMR meter with the pertinent usage and customer information. D.P.U. 13-83-A Page 6 opt-out customer choose to revert to an AMR meter, National Grid proposes a reinstallation fee of $26.00, which includes the cost of removing the non-AMR meter and replacing it with an AMR meter (Exh. NG-MJC-1, at 6). 3.
Proposed Residential Gas Opt-Out Tariffs National Grid proposes that residential gas customers who choose to opt out of their AMR meter pay an installation fee of $67.00 (Exh. NG-MJC-1, at 7). The Company states that this fee includes the Company’s incremental labor costs to remove an existing AMR gas meter and replace it with a non-AMR gas meter (Exh. NG-MJC-1, at 7). The Company also proposes that gas opt-out customers’ bills reflect an additional $13.00 monthly charge for gas meter reads (Exh. NG-MJC-1, at 7). National Grid states that this monthly fee includes the incremental labor costs associated with Company employees manually reading the non-AMR gas meter, as compared to costs associated with reading AMR gas meters (Exh. NG-MJC-1, at 7). Should a gas opt-out customer choose to revert to an AMR meter, National Grid proposes a reinstallation fee of $67.00, which includes the Company’s cost to remove the non-AMR meter and replace it with an AMR meter (Exh. NG-MJC-1, at 7). 4.
Proposed Fee Calculation National Grid states that it calculated the proposed installation fees by multiplying the sum of the average travel and “wrench time” (time worked on the customer’s premises) for a meter exchange by the average straight-time hourly rate of a full-time employee qualified to do a meter exchange (Exh. NG-MJC-1, at 7-8). The Company states that it calculated the proposed monthly meter read fees by multiplying the sum of the average travel and wrench time for a manual meter read by the average straight-time hourly rate of a full-time employee qualified to D.P.U. 13-83-A Page 7 perform a meter read (Exh. NG-MJC-1, at 8). Lastly, the Company states that it set the AMR re-installation fees equal to the respective non-AMR installation fee because it assumes that this procedure requires the same amount of time, and the same type of employee, as is required for the initial AMR meter removal and non-AMR meter installation (Exh. NG-MJC-1, at 9). The Company states that both the proposed installation and meter read fees for AMR gas meters are higher than corresponding fees for AMR electric meters because the labor times for gas meter exchanges and manual gas meter reads are higher than those for electric meters (Exh. NG-MJC-1, at 8). The Company contends that the average wrench time for a gas meter exchange is 40 minutes compared to 13 minutes for an electric meter exchange, and that the average time to perform a manual gas meter read is 12 minutes, compared to 8 minutes for an electric meter (Exh. NG-MJC-1, at 8).
[]we address the Attorney General’s following five arguments: (1) the charges proposed by the Company applicable only to residential customers are unduly discriminatory; (2) the proposed charges will be unjust and unreasonable, allowing the Company to earn a return higher than its allowed return; (3) the proposed charges fail to take into account reductions in costs associated with non-AMR meters; (4) the Department should not establish new surcharges in between base rate cases for services that are substantially similar to those already being charged through existing rates; and (5) the Department should not establish new rates for existing services without a cost allocation study.
National Grid has properly identified the incremental costs to provide this opt-out service, specifically (a) the labor costs to change out the meters and (b) the labor costs to manually read the non-AMR meters (Exh. NG-MJC-1, at 6-9). See of service is a well-recognized basis for rate design). American Hoechest , 379 Mass. at 411 (cost To date, the Company has received 24 requests for a change out of AMR meters (20 residential electric customers, 4 residential gas customers) (Exh. NG-PTZ-1, at 3-4; Tr. at 84-86). Although this number is small, the Department recognizes that, as the use of smart meters has increased nationwide, so too has the need for public utility commissions to address related opt-out issues.6 Thus, we find that there is a reasonable likelihood that the number of National Grid customers pursuing opt-out service will increase. Because customers will be taking a new service from the Company priced at the cost of providing the service, the Department does not find that National Grid’s opt-out service is unduly discriminatory.
[]National Grid’s proposed tariffs are designed to send price signals to customers who are considering opting out of service with an AMR meter (Exh. NG-PTZ-1, at 5). We find that the costs included in the proposed tariffs are reasonably related to the incremental cost of taking service without AMR meters, for those customers who already have AMR meters. See Bertone , 411 Mass. at 546, citing American Hoechest , 379 Mass. at 411 (cost of service is a “well-recognized basis” for rate design). Thus, we find that, in this circumstance, sending an appropriate price signal to customers considering opting out of AMR meters warrants establishing these opt-out tariffs.
The opt-out service proposed by National Grid is for a new service: opting out of service with AMR meters and taking service with non-AMR meters. The Company has identified 9 The typical useful life of a gas meter is approximately 32 years, and the typical useful life of an electric meter is approximately 22 years (Tr. at 38). D.P.U. 13-83-A Page 19 sufficiently particularized circumstances to justify proposing a new service. In proposing its opt-out service, the Company has appropriately set charges based on the identified incremental costs to provide this service to residential customers. In this circumstance, we find that a cost allocation study is not needed.
[]The Company properly designed its opt-out service tariffs to send price signals to customers of the costs associated with opt-out service. The Department has found that fees for various services must be based on the costs that a company actually incurred associated with these functions.
[]In addition, the Department has found that the costs to provide a service should be charged to the customers that cause the cost, rather than be subsidized by other customers.
Here is a copy of section of the notice that was sent to customers seeking to opt out of the first-generation AMR meter from the DPU docket;
Description of Services Unless otherwise determined by the Company, all residential premises shall be equipped with a meter that employs Automatic Meter Reading (“AMR”) technology utilizing radio frequency transmitters to allow the Company to obtain meter readings remotely. However, residential customers may choose to “opt-out” by having their AMR meter replaced with a non AMR meter. At the customer’s request, the Company shall exchange the existing AMR electric meter at the customer’s location and install a non-AMR meter for the purpose of billing electric service to the customer. Upon receipt of the Customer’s request, the Company shall use its best efforts to exchange meters as soon as possible after receiving the request. However, the Company reserves the right to flexibility in scheduling the meter exchange in an appropriate manner based on resource availability. Customers who choose to opt-out will be charged an initial fee for the removal of the existing AMR meter and the installation of the non-AMR meter, pursuant to the Schedule of Charges below. Customers who choose to opt-out will also be charged a monthly meter reading fee for the non-AMR meter, pursuant to the Schedule of Charges below. The Company, at its option, may choose to read the non-AMR meter less frequently than once per month. In that case, or if the Company is unable for any reason to read the meter on the regularly scheduled monthly read date, the Company shall make a reasonable estimate of the consumption of electricity during those months when the meter is not read, based on available data, and such estimated bills shall be payable as rendered. The monthly meter reading fee will be charged on estimated bills. The Company will not assess any fees until after the Company has installed the non-AMR meter. Any opt-out customer who subsequently wishes to have an AMR meter re-installed will be charged a “re-installation fee” pursuant to the Schedule of Charges below. The re-installation fee will be charged for the removal of the non-AMR meter and the installation of an AMR meter. After an AMR meter has been re-installed, the Company will terminate billing the monthly meter reading fee.
MA DPU 13-83 on the one hand claims that that surcharges are based on actual costs, but then the utility took leeway to not read the meters every month, to estimate billing, but still charge the customers the monthly charge.
During covid, the meters were not read at all, and customers received estimated readings and a surcharge.
The initial filing from the DPU stated,
“In addition, the Company may be unable to read the non-AMR meter every month, based upon the location of the meter, in which case an estimated read will be used.”
It is unclear if there has been any effective evaluation or oversight.
For many years, in many locations, a portion of utility customers have read their own meters. There is no reason why the Commonwealth cannot provide a self-read meter to customers who require accommodation, at no extra charge, especially for the lower consumption consumers who do not have reasonable load to shed.
Opt out customers are in fact paying twice, for the punitive surcharge, and for the technology and infrastructure that is of no benefit to them.
Thank you for your kind attention, Patricia Burke
More:
Read: MA Smart Meter Bill Testimony of Lisa Ottaviano
Watch/Listen: (there were some technical difficulties.; you can scroll to each comment)
19:15: Cece Doucette 24:09: Courtney Gilardi 27:31: Lisa Ottaviano 29:31: Amelia Coco Gilardi 33:42: Kirsten Beatty 37:51: Patricia Burke 42:43: Jean Lemieux 50:06: Anna Nelson 1:03:41 Helen Walker
QUICK ACTION, Please sign the Change.org Petition asking the MA Legislature to Pass 2 EMF-Related Bills: Smart Meters and Registry of Harm
Petition · MA Legislature: Pass Smart Meter and EMF Health Harm Registry Bills - United States · Change.org
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Why We Do What We Do:
In this article, we defined the concept of the smart grid and the benefits to society. We also highlighted the importance of radio networks to the successful deployment of the smart grid. We discuss the important concepts of RF energy and the impact on humans. Specifically, there is no demonstrated long term impact of low level non‐ionizing energy on humans. Ionizing energy, beginning with the ultraviolet component of sunlight, has been demonstrated to have long term impact, but the frequencies citing in this report are hundreds of orders of magnitude below that of sunlight. Therefore, this shows that the often quoted sources in the media expressing concern about the RF safety from smart meters are shown to be based on faulty logic, or faulty “facts” and misrepresentations. [] “So when confronted with complaints that say smart meters cause a variety of health effects, ask the complainant to produce the science to support the claim. The conversation should end shortly thereafter.” - No Health Threat From Smart Meters by Klaus Bender. PE Director of Standards & Engineering Utilities Telecom Council (2010) 9 pages