BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Application of Pacific Gas and Electric Company for Approval of Modifications to its SmartMeterTM Program and Increased Revenue Requirements to Recover the Costs of the Modifications (U39M).

Application 11-03-014 (Filed March 24, 2011)

And Related Matters.

Application 11-03-015 Application 11-07-020

MOTION OF CENTER FOR ELECTROSMOG PREVENTION FOR AN ORDER TO COMPEL SDG&E TO PROVIDE REASONABLE PROCEDURES FOR RATEPAYERS OPPOSING SMART METER INSTALLATION

MARTIN HOMEC Attorney for Center for Electrosmog Prevention P. O. Box 4471 Davis, CA 95617 Tel.: (530) 867-1850 Fax: (530) 686-3968 E-mail: martinhomec@gmail.com
CEP Motion for Meter Reading Procedures

March 28, 2013

This motion is submitted pursuant to Rule 11.1 of the California Public Utilities Commission (CPUC) Rules of Practice and Procedure by the Center for Electrosmog Prevention (CEP) for an Order compelling San Diego Gas and Electric Company (SDG&E) to provide ratepayers with reasonable access to their premises, to prevent SDG&E from threatening ratepayers who have chosen to opt out of having a smart meter, and to prevent SDG&E from demanding continuous access to the ratepayers billing electric and gas meters because that impacts the privacy and security of the ratepayers' property and restricts use of the ratepayers' full use of their property. SDG&E is telling opt-out customers whose meters are located inside fenced yards with dogs that they must keep the yard accessible to SDG&E all the time, even at night, with no loose dogs inside their yards EVER. They must kennel the dogs or keep them in the house at all times. This means the homeowners cannot use their yard for their dogs to run free. This type of request is NEW to CEPs members. SDG&E told one customer that SDG&E would be performing "spot-checks" for the dogs being loose in the yard, and if they found the homeowner out of compliance 24/7 [at any time of the day, night, week or month], their electricity would be shut off. SDG&E told the customer that SDG&E would also be performing "spot-checks" for the gate being locked with the ratepayers' lock [which is located low and may only be locked from inside, by design, to prevent it from being cut and removed by thieves, when they are not at home], and if they found the homeowner out of compliance, their electricity would be shut off. SDG&E is telling opt-out customers, whose meters are located inside fenced yards, including those with dogs that they must not lock the gate or if they do, they must use a special lock SDG&E has a key to. That means that SDG&E has a key to the yard at all times and may leave the gate open, as some of the customers have noted has occurred before when SDG&E had access. Some of the customers do not want SDG&E to have this much access and risk the loss of property when gates are left open. Customers must lock gates due to risk of crime. One of these ratepayers lives in a high crime area. They cannot leave the gate unlocked or the lock accessible to potential thieves, even when locked, whether they are at home or not (as it can be cut off). The lock is located on the inside, low on the gate, therefore. They do not want SDG&E to have a key to a lock as they feel their privacy and security would be impinged upon.
CEP Motion for Meter Reading Procedures 2

In any event SDG&E could not reach the lock from the outside. They want to continue to selfread, which worked without a single problem, for 31 years in that same location. They always paid their bill on time and faithfully left the meter reading card on the screen door in front of the house. SDG&E began telling these customers this after they opted out and never before, when they had analogs before smart meters. These customers feel like they are being harassed because they opted out. They want the full use of their properties, with privacy and security in place. They are willing to self-read their analog meters or to set reasonable appointments with meter readers. SDG&E is telling opt-out customers whose meters are located inside fenced yards that they may no longer self-read and that self-reading is not an option, as SDG&E claimed, with one if these customers, "that the CPUC doesn't allow it anymore". If that is so, CEP wants to see the policy and why it was made. We do not believe it exists. Before the smart meters, when these customers had analog meters, some not long ago, they were self-reading with a simple system of SDG&E's that worked for 31 years for one of these customers. They had a card with dials that moved. They matched the dials on the first of the month to the dials on the analog meter and set the card on the front screened door. The meter reader came by and read the card once a month. There was a true-up by appointment several times a year. There was never a single problem. SDG&E is making it very hard for one of these customers to set an appointment, making them spend a very long time on the phone to do so. One of the customers had to take several days off from work as the first day she took off from work when the meter reader was supposed to be there, the meter reader didn't show up. In fact, they were told that meter readers are no longer used, that people from the smart meter opt-out department are going out to read the optout meters. They feel they also are getting the run-around setting up appointments, which is very time-consuming and frustrating. One of these SDG&E customers had been receiving huge estimates (double their usual use which was proven when the analog meter was finally read), because SDG&E refused to allow them to self-read or have appointments to read. These customers feel that SDG&E may

CEP Motion for Meter Reading Procedures

have deliberately raised the estimate as another form of harassment for them, as opt-out customers. When CEPs Director, Susan Brinchman, recently spoke to a local SDG&E "meter reader", she asked if everyone was happy with the opt-out. The meter reader told her that everyone was except those with inaccessible meters in their backyards, and the meter reader then laughed in a most unpleasant manner. CEP has heard these complaints recently and similar ones last fall. CEP challenges the idea that self-reading is forbidden by the CPUC, as selfreading has come up multiple times (CEP has brought it up as a partial solution for reducing opt-out costs), and at no time was it entered into the record that CPUC forbids self-reading. In fact, the only comment of the utilities was consistently, that self-reading isn't offered anymore, that it isn't an option anymore ("we don't do that now"). This indicated it was at the option of the utility and they didn't wish to offer it. Some excuses were given such as it didn't work well, etc. CEP challenges these new requirements and the idea that the utilities can restrict homeowners from ever allowing their dogs to run freely on the homeowners' own property. CEP challenges the concept that becoming a customer for a utility that is a monopoly, which is required to occupy a home, means that the homeowner cannot exercise rights to security and use of property. CEP challenges the way appointments are made and kept, causing people hours of trouble and missed days from work, losing income in the process. CEP challenges the statement that CPUC requires all of the above, and that CPUC can require it. CEP challenges these new requirements as they have never been enforced in this manner before the opt-out. CEP believes that the opt-out customers are being singled out and harassed in a variety of ways, in order to undermine the opt-out and drive up costs. CEP objects to the lack of support SDG&E is showing towards the opt-out and to these practices that discourage people from opting out or make it impossible.

CONCLUSION The choice SDG&E has given the customers is to comply or to return to using smart meters. CEP wants the CPUC to work with SDG&Es ratepayers to allow the ratepayers to use analog meters instead of smart meters without the inconvenience of providing continuous access to their premises and unlawfully losing the use of their yards, which is not the intent of any law. CEP asks the CPUC to direct SDG&E to allow its ratepayers with access issues to read their analog meters themselves and allow SDG&E conveniently scheduled access to verify the
CEP Motion for Meter Reading Procedures 4

reported readings. Lastly, CEP requests that CPUC direct SDG&E to be supportive with the optout customers and treat them with respect. Respectfully submitted, /S/ MARTIN HOMEC Attorney for Center for Electrosmog Prevention P. O. Box 4471 Davis, CA 95617 Tel.: (530) 867-1850 Fax: (530) 686-3968 E-mail: martinhomec@gmail.com March 28, 2013

CEP Motion for Meter Reading Procedures