September 10, 2016

Ronald M. Powell, Ph.D.

How Maryland Customers May Oppose Pepcos Requested Rate

Increase to Pay for the Wireless Smart Meter System
Applicable to any Pepco customer in Maryland but with comments specific to
Montgomery Village, Maryland
This document addresses the following questions. You may jump directly to the answers to any of these
questions by clicking on the question.
What are Wireless Smart Meters, and why are they of concern?
How big a rate increase is Pepco requesting?
How can you estimate the size of your increase?
What must happen for Pepcos requested rate increase to be approved?
What can you do to eliminate, or reduce the size of, Pepcos rate increase? Send a letter! And sign an
online petition!
What additional arguments can you make against Pepcos requested rate increase in your letter?
What about customers who Opted Out of having a Wireless Smart Meter?
When should you send your letter, or sign the petition, opposing Pepcos rate increase?
Should you notify anyone that you have sent your letter?

What are Wireless Smart Meters, and why are they of concern?
A Wireless Smart Meter is an electric utility meter installed on or inside your house, townhouse,
condominium, or apartment building. It measures the amount of electricity that you use. Each Wireless Smart
Meter contains a wireless transmitter/receiver that reports your electricity usage to your electric power
company many times per day by sending radiofrequency/microwave transmissions. Those transmissions are
relayed from one Wireless Smart Meter to another throughout a given community through what is called a
mesh network until they reach an antenna of the electric power company that forwards the data back to the
company. The mesh network is a type of Local Area Network or LAN. Each Wireless Smart Meter in our area
of Montgomery Village also contains a second transmitter/receiver. It is designed to communicate with
wireless devices within your home. It is a form of Home Area Network or HAN. The Wireless Smart Meter
System is also called the Advanced Metering Infrastructure or AMI.
The LAN transmitter/receiver operates in a band of frequencies close to 900 megahertz (MHz). The LAN
transmitter transmits thousands of bursts of radiofrequency microwave radiation every day, night and day,
forever. The HAN transmitter/receiver operates in a band of frequencies close to 2.4 gigahertz (GHz). To the
best of my knowledge, the HAN transmitter has not yet been activated; but it is also capable of transmitting
thousands of burst of radiofrequency/microwave radiation every day, night and day, forever. Both the LAN
and the HAN transmitters are entirely under the control of Pepco. You, as the customer, have no control over
them or over what information they gather about you and your family.
Each Wireless Smart Meter installed in our area of Montgomery Village also contains what is called a service
disconnect switch. This switch is operated remotely by radio signals sent by Pepco through the LAN receiver
in the Wireless Smart Meter. This switch enables the electric power company to shut off all electric power to a
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given customer by sending a wireless signal to his meter, without the need to appear on the customers
property. This switch reduces the cost to Pepco of shutting off all electric power to a residence when that
residence changes hands. This switch also enables Pepco to discipline a customer during a billing dispute, by
turning off all electricity to the customers residence.
The Wireless Smart Meters have given rise to a host of concerns:

Health Concerns: The radiation produced by the radiofrequency/microwave transmitters in the

Wireless Smart Meters has given rise to health concerns.

Privacy Concerns: The amount of information collected by the Wireless Smart Meters about
electrical activities with in a home has given rise to privacy concerns. So much information is collected,
and broadcast over the air, about energy consumption throughout the day that the data enable
determining, for example, when the house is occupied and when it is not.

Cyber Security Concerns: The wireless nature of the Wireless Smart meters has given rise to cyber
security concerns, particularly with regard to the disruption of electricity service through the triggering
of the service disconnect switch.

Reliability Concerns: The complexity of the Wireless Smart Meters, which are much like computers
with built in transmitters and receivers, has given rise to reliability concerns, because the Wireless
Smart Meters have a much shorter lifetime than the traditional analog mechanical meters with no
wireless communications capability that were replaced by the Wireless Smart Meters.

Fire Safety Concerns: The Wireless Smart Meters appear to lack the high degree of tolerance for
electrical surges that the prior analog meters possessed. Also, the poor method used by Pepco when
installing the Wireless Smart Meters (sometimes called hot installation) may have increased the risk
of meter fires from damaged electrical contacts.
In my view, the most serious of these concerns relate to health, because it is impossible for anyone with a
Wireless Smart Meter, or with neighbors with Wireless Smart Meters, to avoid the thousands of bursts of
radiofrequency/microwave radiation that they produce every day. That radiation travels through walls and
strikes every member of every family, day and night, forever. That radiation blankets entire communities that
have Wireless Smart Meters.
If you would like to learn more about these concerns, read further in this document and see also documents
(6), (3), (4), and (5), accessed through the index on the following web page:
https://www.scribd.com/document/291507610/
In comparison, the traditional analog mechanical meters with no wireless communications capabilities,
which Pepco replaced with the Wireless Smart Meters, gave rise to none of these concerns. Those analog
meters were rugged, reliable, accurate, safe, and inexpensive.
It is for all of these reasons that tens of thousands of electric power customers throughout Maryland have
elected to protect themselves and their families by choosing NOT to have Wireless Smart Meters. They are
permitted to do so because Maryland customers argued for, and won, a right for all electric power customers
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in the state to Opt Out of having a Wireless Smart Meter. However, the electric power companies, backed up
by their regulatory body, the Maryland Public Service Commission, require payments, forever, for that
privilege. The Opt Out terms are described in detail beginning on page 7.

How big a rate increase is Pepco requesting?

Pepco is seeking an increase of $15.80 per 1000 kWh of electricity consumption per month. The principal
purpose is to reimburse Pepco for the costs of the Wireless Smart Meter System (also called the Advanced
Metering Infrastructure, or AMI) that Pepco forced on its customers, plus allowable profits. The Wireless
Smart Meters were installed on every housing unit in Montgomery Village beginning at the end of 2012 and
continuing into 2013, with the exception of those housing units of the residents who elected a paid Opt Out,
which is described on page 7 of this document.

How can you estimate the size of your increase?

To get an idea of the size of your increase for any given month, look at your bill for that month and locate the
Total Use figure in kilowatt-hours, abbreviated kWh on the Pepco bill. Divide that number by 1000 kWh,
and multiply the result by $15.80. Here are some examples:

Example 1, for any single month

My August 1996 bill showed that I used 1200 kWh. So my rate increase for August will be $18.96:
(1200/1000) x $15.80 = $18.96.

Example 2, for one year

For the past year, I used an average of 1034.17 kWh of electricity per month. So, if I consume
electricity at the same rate in the coming year, my average monthly rate increase will be $16.34 per
month, or $196.08 for the year: (1034.17/1000) x $15.80 x 12 = $196.08.

Example 3, for all housing units in Montgomery Village

If all of the 14,548 housing units in Montgomery Village consume electricity at this same rate, the cost
of the rate increase for them all for a year, will be $2.85 million per year for the indefinite future:
$196.08 x 14,548 = $2.85 million per year.
One factor that might lower this total is the presence of many townhouses and apartments in
Montgomery Village which would likely consume less electricity than my single-family home. One
factor that might increase this total is that the average occupancy per housing unit is 2.6, which is
greater than the 2 occupants in my home.
So I would guess that the cost increase for all housing units in Montgomery Village, together, would be
somewhere between $2 million and $3 million per year for the indefinite future. That is quite a drain
on the resources on our community, and is not going to help residents to keep up with their quarterly
assessments for living in Montgomery Village, or with their many other expenses.

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What must happen for Pepcos requested rate increase to be approved?

The Maryland Public Service Commission, which regulates all Maryland utilities, has the authority to approve,
disapprove, or adjust the amount of Pepcos requested rate increase. To gain the PSCs approval for Pepcos
requested rate increase, Pepco, strictly speaking, must PROVE to the PSC that each $1 spent on the Wireless
Smart Meter System has returned more than $1 of total benefits to the customer. Pepco is claiming that each
$1 it spent is returning $3.54 in "total benefits" to the customers. Pepco claims that the benefits of the
Wireless Smart Meter System "are leading to an enhanced customer experience through":

"better and more easily accessible data about how they use electricity"
"more immediate feedback and customized care from customer service representatives"
"improved outage restoration time during storms through use of 'meter pinging' to identify when
meters are on"
serving "as a foundation for many other future applications such as microgrids, smart street lighting,
pre-pay programs, home area networks, distributed generation and electric vehicles."

Reference: Pepco's claims of these benefits are described in Pepcos request for the rate increase which is
document 1 on the Maryland Public Service Commission web site for Case Number 9418 on the list of
documents found here:
http://webapp.psc.state.md.us/newIntranet/casenum/CaseAction_new.cfm?CaseNumber=9418
Under document 1, click on See more. Then download the file
2016PepcoMDRateCaseApplicationDirectTestimonyandExhibitsVolIofII041616.pdf
which is Volume I of II. Read through the first 6 pages, but read page 3 especially.

What can you do to eliminate, or reduce the size of, Pepcos rate increase? Send
a letter! And sign an online petition!
Send a letter!
The Maryland Public Service Commission (PSC) is soliciting public feedback on the rate increase. That
feedback may be provided by individual customers simply by sending a letter to the PSC.
If you feel that your Wireless Smart Meter is "leading to an enhanced customer experience" for you
that is worth a rate increase of $15.80 per 1000 kWh of electricity that you use per month, for the
indefinite future, you need do nothing. Your non-response will be regarded as a lack of concern about
the increase, and thus as a tacit assent to the increase.
However, if you DO NOT feel that your Wireless Smart Meter is "leading to an enhanced customer
experience" worth $15.80 per 1000 kWh of electricity that you use per month, for the indefinite future,
and you would prefer NOT to have this rate increase, then you MUST write a letter to the Maryland
Public Service Commission (PSC) for your opposition to be noted. That letter should be mailed to the
PSC. The letter cannot be submitted as an email message. A suggested format for your letter is
provided below:

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(date)
David J. Collins, Executive Secretary
Maryland Public Service Commission
William Donald Schaefer Tower
6 Saint Paul Street, 16th Floor
Baltimore, MD 21202-6806
RE: Case Number 9418, In the Matter of the Application of Potomac Electric Power Company for Adjustment
to Its Retail Rates for the Distribution of Electric Energy
Dear Mr. Collins:
I oppose the rate increase requested by Pepco in Case No. 9418 because the Wireless Smart Meter System has
not provided the enhanced customer experience that Pepco claims.
(If you wish, you may add other arguments against the rate increase, as discussed below.)
Sincerely yours,
(your signature)
(your printed name)
(your full address)

In addition to letters from individual customers, the PSC solicits the views of organizations on a more formal
basis. These organizations can file as intervenors and can provide extensive documentation. They may then
present their views orally at a series of hearings for the intervenors that will held by the PSC in coming weeks.
Already, the City of Gaithersburg and the City of Rockville have filed as intervenors, among other
organizations.

Sign an online petition!

You may also wish to sign an online petition, advocated by Roger Berliner, a Montgomery County
Councilmember. That petition can be found by clicking HERE or on the full URL below:
https://www.change.org/p/kevin-hughes-fight-the-hike-dbe0899d-7d21-47b8-aa8bccc67ad71ef3?tk=MX0nB_8Opx_F2IFVahwd8oDi718CNlbhpSKInlAHg74&utm_source=petition_update&utm_
medium=email

What additional arguments can you make against Pepcos requested rate
increase in your letter to the PSC?
You may make as many arguments as you wish against the rate increase. You may compose your own
arguments, of course. Or you may use some of the suggested arguments below, or modifications that you
make of them. Whatever you wish. Your decision to use any of the arguments below may depend on your
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familiarity with Wireless Smart Meters and with the many promises that Pepco has made to its customers
about the savings that the meters were going to bring.

I have not found that the data from my Wireless Smart Meter, reported back to me through my
account on the Pepco web site, to be useful in reducing my consumption of electricity.

I don't need data from my Wireless Smart Meter, reported back to me through my account on the
Pepco web site, to know how to reduce my consumption of electricity.

If the Wireless Smart Meter System were really saving money, a rate reduction would be the
appropriate response, NOT the rate increase that Pepco is requesting.

The fact that Pepco is seeking a rate increase to recover the cost of the Wireless Smart Meter System is
evidence that the Wireless Smart Meter System did not reduce the cost of meter reading enough to
pay for the System, and therefore that the rate increase is not justified.

The fact that the Wireless Smart Meter System could not pay for it own costs in savings, EVEN AFTER
the Federal Government shared in the costs of the Wireless Smart Meter System by providing funds to
Pepco through the stimulus bill of 2009 (The American Recovery and Reinvestment Act of 2009), is
further evidence of the lack of a justification for a rate increase.

The Wireless Smart Meter on my home was installed without seeking my prior approval. The cause of
any increased cost is, therefore, a consequence of Pepco's decision, not my decision. As the cause of
any cost increase, Pepco itself should bear the increased cost of the Wireless Smart Meter System and
not attempt to transfer that cost to the customer.

Pepco's substitution of the Wireless Smart Meter System for the more rugged and reliable "traditional
analog mechanical meters with no wireless communications capability" clearly has INCREASED the cost
of Pepco's services to the customer, and without any compensatory benefits to the customer. This is
evidence that the imposition of the Wireless Smart Meter System was a MANAGEMENT MISTAKE made
by Pepco. That is, Pepco itself is the CAUSE of its own rate increase, and, according to the principal of
COST CAUSALITY, which Pepco and the PSC regularly cite, Pepco itself should bear all of the costs of
this MISTAKE, not the customers.

For decades, Maryland customers for electric power have accepted the right of the electric power
companies to measure their use of electricity once a month for the purpose of issuing monthly bills.
But when Pepco, with the approval of the Maryland Public Service Commission, mandated the
installation of Wireless Smart Meters on every home in their service area, Pepco effectively claimed a
whole set of NEW RIGHTS that were never approved by the customers. Specifically, Pepco claimed the
right:
o To install Wireless Smart Meters whose radiofrequency/microwave emissions had never been
proven safe for human beings, pets, and other living things.
o To irradiate everyone in the home, including even pregnant mothers and babies in cribs, and the
neighbors, too, with radiofrequency/microwave radiation at a frequency of 900 MHz, which is a
frequency already shown to have biological effects, and which has most recently been shown by
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the National Toxicology Program at the National Institutes of Health to be a "likely" cause of
malignant brain cancer and benign nerve tumors.
o To include in each Wireless Smart Meter, a second transmitter, operating at 2.4 GHz, designed to
communicate with other wireless devices inside the home -- whether the customer wants that
intrusion or not -- with both health and privacy consequences.
o To measure electricity consumption, as often as the power company desires, and to broadcast
those readings over the air, turning the Wireless Smart Meter into a surveillance device that reveals
such invasive information as when the home is occupied and when it is not, compromising both
privacy and personal security.
o To include in each Wireless Smart Meter a wirelessly controlled "service disconnect" switch,
capable of cutting all power to the home, degrading the cyber security of the reliable delivery of
electric power to the home.
o To install the Wireless Smart Meters "hot", that is, without turning off all circuit breakers in the
home first to assure that the home is drawing no current through the meters when they are
swapped. Because installation was done "hot", arching could have occurred which could have
damaged meter contacts and meter-box contacts, increasing the risk of meter fires from then on.

What about customers who Opted Out of having a Wireless Smart Meter?
Because of the health, privacy, cyber security, and fire safety concerns raised by Wireless Smart Meters,
Maryland residents, through Maryland Smart Meter Awareness (http://MarylandSmartMeterAwareness),
fought for, and won, from the Maryland Public Service Commission, the right for all Maryland homeowners to
Opt Out of having Wireless Smart Meters on, or inside, their homes. But the electric power companies
demanded, and the PSC agreed, that the customers much pay fees for the privilege of NOT having a Wireless
Smart Meter, that is, for preferring no change in their metering status at all.
If you are one of the Pepco customers who has Opted Out of a Wireless Smart Meter, here are some
suggested additional arguments you may want to include in your letter to the PSC. Feel free, of course, to
modify these suggestions in any way you wish, or to write your own versions entirely:
As a Pepco customer who has elected to Opt Out of having a Wireless Smart Meter, I oppose the rate
increase requested by the Pepco for these additional reasons:

I have paid Pepco an initial fee of $75, and I continue to pay a monthly fee of $14 per month,
forever, NOT to have a Wireless Smart Meter. I should not also have to pay the rate increase for
the Wireless Smart Meter System, which I do not use. That is, Pepco caused all of the increased
expenses associated with the Wireless Smart Meter System, not the customers; and the customers
who have Opted Out should not have to pay BOTH to HAVE a Wireless Smart Meter and AND NOT
TO HAVE a Wireless Smart Meter, simultaneously. For customers who have Opted Out, either the
requested Pepco rate increase should be zeroed, or the Opt Out fees should be terminated.

Pepco's claims of a financial benefit to the customer from the installation of the Wireless Smart
Meter System do NOT account for any of the consequential costs to the customer that have
resulted from Pepco's mandatory installation of the Wireless Smart Meter System, including:
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o Costs of medical care and decreased quality of life for those customers whose health has been
harmed by the radiofrequency/microwave radiation emitted by the Wireless Smart Meters.
o Compensation for the costs incurred by customers driven out of their homes by the radiation
from the Wireless Smart Meter System.
o Compensation for the increased risks associated with the other drawbacks brought by the
Wireless Smart Meter System, including risks to privacy, to cyber security, to the reliability in
the delivery of electrical power, and to fire safety.

When should you send your letter, or sign the petition, opposing Pepcos rate
increase?
Sending your letter sooner is better than later, to provide time for your letter to be reviewed. But your letter
must be received at the Maryland Public Service Commission no later than October 21, 2016.
Signing the online petition sooner is also better than later. Already thousands of signatures from Pepco
customers have been received.

Should you notify anyone that you have sent your letter?
If you wish to let me know that you have sent your letter, I would be pleased to hear from you.
Regards,
Ronald M. Powell, Ph.D.
Montgomery Village, MD
Email: rmp2x7@verizon.net

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