Application No: A.11-03-014, and Related Matters Exhibit No.

: CEP-1 Witness: Susan Brinchman

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

PREPARED DIRECT TESTIMONY OF SUSAN BRINCHMAN ON BEHALF OF CENTER FOR ELECTROSMOG PREVENTION

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA October 5, 2012

CEP Testimony

I. QUALIFICATIONS ........................................................................................................................................ 3 II. PURPOSE ................................................................................................................................................... 4 III. PROPOSED FEE STRUCTURE ..................................................................................................................... 5 IV. QUESTIONS POSED IN AMENDED SCOPING MEMO................................................................................ 8 a) What are the utility costs associated with offering an analog meter opt-out option?........................ 8 Cost of Meters....................................................................................................................................... 9 Back Office Costs...................................................................................................................................9 CPUC OVERSIGHT................................................................................................................................12 RELIABILITY..........................................................................................................................................13 COST OF METER-READING .................................................................................................................. 14 b) Should more than one opt-out option be offered to customers who do not wish to have a wireless smart meter (e.g., a digital, non-communicating meter)? ..................................................................... 14 c) Should all costs associated with the opt-out option be paid by only those customers electing the option, or should some portion of these costs be allocated to all ratepayers and/or to utility shareholders?......................................................................................................................................14 d) What fees should be assessed on customers who elect the opt-out option and should the fees be assessed on a per meter or per location basis?..................................................................................15 e) Should there be different fees based on whether the customer is selecting to opt-out of a single commodity or two commodities?....................................................................................................... 15 f) Should there be an exit fee imposed on customers who elect the opt-out option and return to a wireless smart meter? ........................................................................................................................16

CEP Testimony

PREPARED DIRECT TESTIMONY OF SUSAN BRINCHMAN ON BEHALF OF CENTER FOR ELECTROSMOG PREVENTION

I. QUALIFICATIONS
My name is Susan Brinchman. I am the Director for the Center for Electrosmog Prevention (CEP). My business address is P.O. Box 655, La Mesa, CA 91944. I received a Bachelors degree in Special Education from the University of Connecticut, and a Masters in Educational Technology from National University. I was employed by the San Diego City Schools for 25 years as a Special and General Education teacher and am now retired. I have 9 years combined experience as founder and environmental nonprofit director for the 501c3 nonprofit Center for School Mold Help (SMH) and (concurrent) charitable nonprofit Center for Electrosmog Prevention (CEP). The purpose of both organizations is to improve the public health through reducing or eliminating preventable toxic environmental exposures by providing prevention, solutions, and advocacy. In the course of teaching special education students, I have seen many thousands of students whose disabilities could be connected with preventable environmental exposures in utero or during the early years of childhood, and who suffered from such medical conditions as asthma, as well as teachers who became disabled or ill due to workplace exposures. It made sense to me to try to intervene to improve the conditions, on a national basis, that were causing these problems. In the case of mold and health, which was previously not officially recognized as a public health risk by federal health agencies, SMH was able to intervene and was instrumental in convincing the Centers for Disease Control (CDC) to accept external independent information pertaining to the public health threat from mold. As a result, CDC changed its entire position on mold, viewing it as a highly undesirable public health risk and promoting more careful handling of mold, which now is more in alignment with current independent science. SMH has also communicated regularly and participated in meetings with United States (US) Environmental Protection Agency (US EPA), conferenced with US Department of Education officials and national teacher union leaders, and corresponded with World Health officials to help bring attention to improvements in policies and public information that would reduce the problem of mold and indoor dampness in schools, and to recognize this problem, and address it more proactively. In many cases, the suggestions helped lead to notable improvements. Thus, as CEP Testimony 3

Director of SMH, I have been able to positively influence the public health with relationship to indoor dampness and mold. CEP was founded in order to reduce exposures to electrosmog, which can be described as a rapidly growing form of invisible and harmful manmade pollution from electromagnetic radiation. Success in these areas, even to a small degree, may conceivably have a strong ripple effect to improve the public health and reduce the healthcare, economic, and societal costs of a growing number of disabled and therefore, less productive individuals, as well as the personal burden of individuals and families who are needlessly suffering from preventable environmental exposures. It is apparent that governmental authorities are the very last to react to decades or even a half century of scientific environmental research, which thus, in great part, is instrumental in causing these costs and burdens to our society. We all benefit when the government is less bureaucratic and more proactive, and this is where educational nonprofits can help make a difference, through participation in the process, often welcomed by government agencies in so doing. Websites: www.electrosmogprevention.org; www.schoolmoldhelp.org

II. PURPOSE
The purpose of my direct testimony on behalf of CEP is to address cost and cost allocation issues associated with providing the analog opt-out option adopted for residential customers in Decision (D.) 12-02-014, D.12-04-018 and D.12-04-019. CEP is questioning the basis for the costs claimed by the utilities for their respective opt-out programs, as these seem inflated and the programs appear not to be conducted efficiently. CEP is proposing a no-fees structure for the investor owned utilities customers who choose to opt-out of an advanced meter. CEP further proposes to have the CPUC hire an independent, mutually agreed-upon entity (with Parties to the Proceeding) to audit the costs and revenues associated with the opt-out program to a memorandum account that is reviewed for accuracy and the invoices checked for competitive procurement practices. The records management practices of the investor owned utilities electric and gas distribution systems are also important in determining whether the utility companies are properly managing the opt-out programs, and should be part of the audit. This audit should be made with full and open transparency to the public, in all its detail, at no cost. CEP Testimony 4

III. PROPOSED FEE STRUCTURE

CEP Concerns:

1)

Definition of "analog" to be used in this testimony: exclusively electromechanical, not electronic, no chip inserted, non-hybridized, zero Radio Frequency (RF) radiation or Electro Magnetic Field (EMF) emissions.

2)

Only use analog meters for opt-outs because smart meters with the radio turned off or a chip inserted, or electronic or digital meters still emit RF radiation. San Diego Gas and Electric Company (SDG&E) proposes using analog meters1, Pacific Gas and Electric Company (PG&E) proposes using analog meters2, and Southern California Edison Company (SCE) proposes using the meter already installed either smart meter with radio off or an analog meter3.

3) 4) 5)

CEP disagrees with any fees for opting out. CEP asserts that no-fee-opt-outs should be offered for all customers, using only analog meters. PG&E has included its smart meter opt-out costs in the 2014 General Rate Case (GRC) forecast that was submitted to the CPUC. CEP is also participating in the 2014 GRC proceeding. The various back office systems that will be required to implement the smart meter program have not been verified by an outside auditor. SCE testimony of T. Walker, pp. 16-19 describes

costs that have not been verified or audited; SDG&E provides the testimony of Charles Snyder, CS-13 through CS-15. CEP believes there is some anecdotal evidence that
unnecessary practices are being utilized that can inflate costs. 6) 7) SCE recommends no reasonableness review after the conclusion of this proceeding4 CEP disagrees and recommends a reasonableness review of all opt-out programs. Ongoing notification of opt-out program, with notification of three month initial time frame to pay5 (if fees are charged, though CEP disagrees with fees) is needed. Continuing to allow

1 2 3 4

SDG&E Testimony of Charles Snyder, p.CS-2, lines 6-8 PG&E Testimony of Stephen H. Phillips, p. 2-1, lines 10-13. SCE Testimony of L. Oliva, p. 1, lines 7-11. SCE witness L. Letizia , p. 26, lines 21-23

CEP Testimony

customers with locked or inaccessible backyards to self-read, as has been customary in recent past and as other utilities employ this practice, is appropriate. It is not appropriate to change the rules, eliminate the practice, or create new punitive rules that cause restriction of freedoms which has the effect of making people who have opted out feel harassed or intimidated if they have a meter in a fenced yard with dogs or do not wish to leave an unlocked gate, opening themselves up to crime. Appointments may also be made, when possible and mutually agreed on. 8) Offering no-fee opt-out for all customers, including, but not limited to those who must opt-out for RF avoidance/medical reasons, as the American Academy of Environmental Medicine (AAEM)6 and other independent RF and EMF experts, scientists, and physicians, have identified health risks from RF, and people may wish to opt-out due to a desire to avoid an unnecessary health risk. Privacy, safety and security concerns may also exist, providing other reasons for a free opt-out. Lastly, there is no federal nor state mandate to have a smart meter, purely voluntary opt-ins were described as a possibility in the federal energy acts, not forced installations with paid opt-outs. 9) Not requesting unlimited 24/7 access to those yards with analog (or smart) meters and requesting that dogs be caged or kept in house 24/7 to allow meter access. Meter readers are on premises about 2 minutes or less. 8 minutes is an exaggeration that inflates costs. Also the utilities should have self-reading as an option and mail it in or enter on computer and send someone twice a year to double check the actual use, by appointment. 10) Use meter reader schedules that are most efficient cost-wise, rather than coming back on another day for a neighboring meter or having two different meter readers, or having a gas meter reader and an electric meter reader, separately. Current practices may artificially inflate costs. 11) The payment and other terms for opting-out are not provided, (or are being stretched to include that which violates property rights and personal privacy) but customers are forced to agree with these without seeing them7. For instance, according to several anecdotal sources, SDG&E has allegedly told opt-out customers that the new terms include 24/7 access to yards, though this
5 6

SCE witness T. Walker, p.19, lines 4-5. http://www.aaemonline.org/

SDG&E witness Snyder, page CS-13 lines 20-21: "allowing safe access to the SDG&E owned meters on a residential customer premise."

CEP Testimony

was never described in advance, is part of no written terms on SDG&E's site for opting out, nor is part of the ruling. 12) The proposal for an exit fee has not been approved by CPUC. Yet, SoCalGas Petersilia recommends adopting an exit fee. CEP disagrees with all fees, including exit fees, as unfair and punitive. 13) Southern California Edison Company (SCE)s testimony by G. Huckaby states8 that there should be no exit fee but instead there should be an increased initial opt-out fee. CEP disagrees with any initial or exit fee as unfair to customers who have been forced to already pay for an analog meter initially, then the smart meter, and often for medical or other compelling reasons, another analog meter, when the first one still had many years of use before they were unjustifiably forced to lose it. Charging an exit fee is punitive and unjust, per California State Utility Code 451. Opting out is often prompted by a desire to avoid exposure to increased Radio Frequency (RF) radiation. RF radiation exposure - especially that from smart meters - and is not recommended by a large group of environmental and other physicians for people with a wide variety of certain medical conditions9. It has been shown that smart meter exposure complaints corresponds with biological and health effects heavily supported in the robust independent, growing scientific literature on radiofrequency radiation exposures. This RF exposure as a health hazard was not taken into consideration. FCC guidelines were inappropriately used to justify this mistaken technological system. FCC guidelines are not only nearly universally considered obsolete (by independent sources including the US GAO10), but are not applicable as these were not developed to protect those with medical conditions nor other fragile populations such as children, nor were they developed for the forced, ubiquitous exposure of a pulse-modulated mesh network involving smart meters that are sending out signals tens of thousands of times daily, at the very least, according to three California utilities, in response to the administrative law judge's request for more

P. 10, lines 9 14. Rather than imposing a separate exit fee to recover the exit costs, SCE proposes recovering the Opt-Out Program termination costs through the initial fee. This approach avoids shifting program costs to nonparticipants, results in lower systems costs related to the establishment and billing of a new exit fee, and lowers the uncollectible expense associated with the collection of an exit fee. SCE estimates that this approach would eliminate a $78 exit fee and increase the initial fee by approximately $20.
9

AAEM Recommendations http://aaemonline.org/AAEMEMFmedicalconditions.pdf http://www.gao.gov/products/GAO-12-771

10

CEP Testimony

information11. Considering there is a robust scientific literature with upwards of what has been described to be 20,000 peer-reviewed studies that show, with the exception of industry-sponsored studies, undesirable biological effects and health effects at from millions of times to thousands of times less than FCC guidelines, and that this type of radiation is used in weaponry due to the biological and health effects that can be stimulated, and due to the fact that there is some significant indication in the literature that shows there is no dose-response relationship, the resulting risk and health complaints could have readily been anticipated by the utilities for wireless technologies. In addition, as has been stated previously, according to federal law12, there has never been any federal plan to force people to all have smart meters, nor has there been a state law that requires this. Rather, a potential future opt-in was suggested, to allow people to have a smart meter if they wished. There was never a mention of any wireless technology in any of the legislation, as it is there that the hazards would have had to be evaluated. Therefore, due to all of the above, and the clear indication that there is a public hazard to RF radiation exposure, the shareholders and company must bear the costs. Further, under various discrimination laws not limited to the Americans with Disabilities Act (ADA), the investor-owned utilities must bear the costs of all opt-outs for those who do not wish to assume health risks and for accommodations for those with the aforementioned medical conditions and disabilities. Lastly, it is not up to the CPUC to determine or waive neither federal or state discrimination laws nor other rights, as they pertain to the people. These are incontrovertible rights that no state agency nor federal agency or other entity may interfere with.

IV. QUESTIONS POSED IN AMENDED SCOPING MEMO

The June 8, 2012, Phase 2 Scoping Memo listed specific issues to be addressed in the Phase 2 testimony. This was modified by an e-mail message on September 28, 2012, from the assigned administrative law judge.

a) What are the utility costs associated with offering an analog meter optout option?
The costs are:
11

RESPONSE OF SAN DIEGO GAS & ELECTRIC COMPANY (U 902 E) ON THE ADMINISTRATIVE LAW JUDGE'S RULING SEEKING CLARIFICATION (Nov. 1, 2011) US Energy Acts 2005, 2007

12

CEP Testimony

1) record keeping practices necessary for operating the utility companies utility distribution systems pursuant to the recommendations of the CPUCs Consumer Protection and Safety Division (CPSD)s made in Investigation (I.) 11-02-016, 2) cost of purchasing a meter if needed, 3) cost of installing the meter, 4) cost of meter reading, 5) cost of billing.

Cost of Meters
Analog meters are available for about $15 on the market, according to our initial research. Utility companies are replacing a smart meter valued at approximately $125 that the customer has already paid for and won't be using, which may be reused. Analog meters have often lasted 50-60 years, with little to no maintenance. Smart meters last 5-10 years, according to our initial research, with high maintenance, as they are a new, untested technology with many defects already noted. They can cause fires, cease to work in various high temperatures, overbill, and have been known already, as a new, untested device, hurriedly rushed to market, to malfunction frequently. It is very likely cheaper for the company to allow customers to have an analog for a variety of reasons.

Back Office Costs

There are no necessary "back office" costs because there is no need to oversee these analog meters except for the purpose of billing customers. There should be no added record keeping costs because the utilities record keeping systems for the electric and gas distribution systems would not have to be modified to include the customers who choose to opt-out of the use of smart meters if the record keeping systems are properly designed or use what has been already developed and used for the past century. The costs of maintaining smart meters and oversight of the California electric grid caused by using smart meters before the California Independent System Operator has the capability of using the smart meters for electric grid operations is far greater than the costs of using analog meters. Analog meters have been successfully used for decades - actually, up to a century or more - with the California electric grid. SB 17, codified and chaptered into California Public Utilities (PU) Code 8360-69, states, It is the policy of the state to modernize the state's electrical transmission and CEP Testimony 9

distribution system to maintain safe, reliable, efficient, and secure electrical service CEP believes that these requirements have not been met, and the CPUC has not required adequate proof of meeting these criteria. On the contrary, the CPUC appears to be accepting unsubstantiated claims of safety, without supportive data and is ignoring all evidence to the contrary, including widespread reports of harm to health, smart meter fires, massive power outages, and the dire warnings of independent experts and scientists related to safety, reliability, efficiency, and security. The CPUC has a statutory obligation to oversee the utilities operations for consumer protection and safety. California PU Code section 330 (f) and (g), section 334, and section 364. Section 364 requires the CPUC to adopt inspection, maintenance, repair, and replacement standards for the distribution systems of investor-owned electric utilities. The CPUC cannot cherry-pick the portions of the SB 17 statute to apply to the smart grid plans, especially ignoring the safety mandates. At the CPUC Business Voting Meeting held on February 1, 201213, a number of citizens have even called the actions of the CPUC Commissioners in not providing safety related to serious harm being perpetrated on customers without taking appropriate preventative or responsive action crimes against humanity14.

13

CPUC Commission Business Voting Meeting - February 1, 2012

Wikipedia: Crimes against humanity, as defined by the Rome Statute of the International Criminal Court Explanatory Memorandum, "are particularly odious offenses in that they constitute a serious attack on human dignity or grave humiliation or a degradation of one or more human beings. They are not isolated or sporadic events, but are part either of a government policy (although the perpetrators need not identify themselves with this policy) or of a wide practice of atrocities tolerated or condoned by a government or a de facto authority. Murder; extermination; torture; rape; political, racial, or religious persecution and other inhumane acts reach the threshold of crimes against humanity only if they are part of a widespread or systematic practice. Isolated inhumane acts of this nature may constitute grave infringements of human rights, or depending on the circumstances, war crimes, but may fall short of falling into the category of crimes under discussion."[1]
14

CEP Testimony

10

At the very least, the CPUC has a statutory obligation to oversee the utilities operations for consumer protection and safety. California PU Code section 330 (f) and (g)15, section 334, and section 36416. Section 364 requires the CPUC to adopt inspection, maintenance, repair, and replacement standards for the distribution systems of investor-owned electric utilities.

15

PUC section 330 (f) The delivery of electricity over transmission and distribution systems is currently regulated, and will continue to be regulated to ensure system safety, reliability, environmental protection, and fair access for all market participants. (g) Reliable electric service is of utmost importance to the safety, health, and welfare of the states citizenry and economy. It is the intent of the Legislature that electric industry restructuring should enhance the reliability of the interconnected regional transmission systems, and provide strong coordination and enforceable protocols for all users of the power grid.

16

Public Utilities Code section 364.

(a) The commission shall adopt inspection, maintenance, repair, and replacement standards for the distribution systems of investor-owned electric utilities no later than March 31, 1997. The standards, which shall be performance or prescriptive standards, or both, as appropriate, for each substantial type of distribution equipment or facility, shall provide for high quality, safe and reliable service. (b) In setting its standards, the commission shall consider: cost, local geography and weather, applicable codes, national electric industry practices, sound engineering judgment, and experience. The commission shall also adopt standards for operation, reliability, and safety during periods of emergency and disaster. The commission shall require each utility to report annually on its compliance with the standards. That report shall be made available to the public. (c) The commission shall conduct a review to determine whether the standards prescribed in this section have been met. If the commission finds that the standards have not been met, the commission may order appropriate sanctions, including penalties in the form of rate reductions or monetary fines. The review shall be performed after every major outage. Any money collected pursuant to this subdivision shall be used to offset funding for the California Alternative Rates for Energy Program.

CEP Testimony

11

CPUC OVERSIGHT

CEP is concerned with the issues of CPUC oversight of the functioning of the Smart Customer/Utility/Market:
How will the CPUC monitor the deployed smart grid for safety, as well as the efficiency and security, and to determine whether the electrical grid is functioning as it should function, to meet the needs of Californians? The recent problems with the natural gas pipeline infrastructure in California show that the CPUC Consumer Protection and Safety Division17 (CPSD) has not overseen the current, traditional utility infrastructure. How will the CPUC analyze the smart grid for errors or faults? Where is the inventory of each component of the smart grid so that it can be monitored? Who will monitor them? A similar problem with the lack of records for the natural gas pipeline infrastructure is the subject of a current CPUC proceeding: Order Instituting Investigation (I.) 11-02-01618. The CPSD staff report in the I.11-02-016 proceeding states that: This review has used the "Generally Accepted Record-keeping Principles" (GARP)19 and the Information Maturity Model20 defined by ARMA International21 as the basis of an assessment and evaluation of PG&Es records management activities. The CPSD report finds that current California utility records management activities didnt meet legal and regulatory standards in that proceeding. Yet the CPUC staff report on the smart grid doesnt address the records keeping legal and regulatory standards in this proceeding.

17 18 19

http://www.cpuc.ca.gov/PUC/aboutus/Divisions/Consumer+Protection/ http://docs.cpuc.ca.gov/published/proceedings/I1102016.htm www.arma.org/garp www.arma.org/garp/metrics.cfm

20 21

ARMA International was previously known as Association of Records Managers and Administrators, and is the authority on managing records and information in the USA (www.arma.org)

CEP Testimony

12

What changes does the CPUC need to make to ensure safe and efficient operation of the electrical grid? CEP feels that implementation of the smart grid is premature, as the technologies selected are inherently unsafe and insecure, and as such, must be rethought, with implementation halted, for the protection of the health and welfare of all citizens of the state, and the United States of America, which may be negatively impacted by what occurs with our electrical grid. CEP feels that the CPUC has shown itself to be extremely negligent in its role as protector of customers and citizens of the state with regards to safety of the emerging smart grid. The CPUC staff recommends that approval of Deployment Plans should be based on strict and complete compliance with the requirements of SB 17 and D.10-06-047. However, CEP notes that the CPUC is required to comply with its statutory mandate too. CEP believes that this means that the CPUC must adopt inspection, maintenance, repair, and replacement standards to maintain safety for the distribution systems of investor-owned electric utilities. This could be done by adopting a new general order or by amending an existing general order. General Orders 165, 166, and 167 appear to be the current regulations addressing these issues, but they have not been updated to address the operation of the Smart Customer/Utility/Market or the smart grid. The addition of smart meters and supporting equipment must be addressed by the CPUC to ensure reliable operations. The current CPUC oversight consists entirely of levying fines and operations orders after a malfunction occurs. This should not continue. Instead, the CPUC should issue effective operational and safety orders as soon as possible.

RELIABILITY
The smart grid plans make it apparent that this is an experiment, that no one knows how it really should unfold, or whether it will work as planned. The plan so far has failed to produce confidence, and with good reasons. A recent demonstration of the fragility and unreliability of the new smart grid was seen in September, 2011, when large parts of California, Arizona, and New Mexico experienced an unprecedented and poorly understood blackout that seriously impacted the safety and economy of those regions. The smart grid cannot be reliable or safe if it is insecure. Former CIA Director Woolsey says the federal government's oversight of grid security is inadequate and attacks on the grid are "entirely possible". He further said, "No one CEP Testimony 13

appears to be in charge of security for the grid, whether it's cyber or transformers or whatever. You can search forever through the federal code to try to find who that person might be. And a so-called 'Smart Grid' that is as vulnerable as what we've got is not smart at all, it's a really, really stupid grid." 22

COST OF METER-READING
Analog meters can be read by the utilities customers to reduce the cost of service, at least most of the year. Currently, some of the analog meters provided for electric utility service in California are read by customers and some of the utilities that are Parties in this proceeding have allowed this, historically, and even recently. The Plumas-Sierra Rural Electric Cooperative, a California utility, has a website explaining that self-reading is easy and is a method to save money for the electric customers: http://www.psrec.coop/electric_read_meter.php?sec=elecser&pag=elecread

b) Should more than one opt-out option be offered to customers who do not wish to have a wireless smart meter (e.g., a digital, noncommunicating meter)?
No, there should only be an analog (purely electromechanical) meter offered. The analog meter is the best choice as it does not emit RF radiation nor increased EMF's on the home wiring (is compatible with older home wiring also), and will be readable by the customer to reduce costs of meter reading. Analog meters may be visually self-read and recorded on a postcard (as has been in current practice in SDG&E territory) or by computer (a future option to be explored).

c) Should all costs associated with the opt-out option be paid by only those customers electing the option, or should some portion of these costs be allocated to all ratepayers and/or to utility shareholders?

22

Woolsey interview with Energy Now http://youtu.be/rIFD1sUTGX8

CEP Testimony

14

All costs should be paid by the company and all shareholders including those costs associated with a customer's special circumstances, for the reasons given above. All costs associated with customers with medical conditions or disabilities that could be impacted by RF radiation or who are in the categories or risk groups that doctors recommend should avoid RF radiation should be paid as required by that legislation. All costs should be born by the company and shareholders as smart meters are not mandated by law (state or federal), have safety, privacy, and security issues that customers were not informed about and did not choose to be subjected to. State law forbids charging extra for safety.

d) What fees should be assessed on customers who elect the opt-out option and should the fees be assessed on a per meter or per location basis?
There should be no fees at all for customers who opt-out, for the reasons stated previously. No one should have to pay not to be irradiated or to preserve their privacy. If customers are allowed to read their own meters and other efficiency methods are utilized, the costs to the companies would be greatly reduced. If fees are charged despite the above, born by the company and its shareholders alone, costs should reflect the reduced trips required by the people reading meters, with highly efficient methods used by the company. Fees should not ever be charged for the opt-outs, but if so, born by the company and its shareholders alone, they should be assessed by location - not per meter - and that would include multi-family dwellings. If those opting-out also read their meters, there would not be a meter reading except for annual or semi-annual meter reading visits by their electric service provider or gas company.

e) Should there be different fees based on whether the customer is selecting to opt-out of a single commodity or two commodities?
CEP asserts that no fees should be charged, for any reason. The fees and costs (if any), born by the company and its shareholders alone, should be determined by the number of required, very efficiently planned, occasional, short trips made to each property, not on unnecessary, inflated or duplicative costs.

CEP Testimony

15

f) Should there be an exit fee imposed on customers who elect the opt-out option and return to a wireless smart meter?
No, all costs related to opting out or opting back in should be paid by the utility's owners and shareholders. This will reduce the likelihood of the utility putting pressure on customers to opt-in or opt-back-in to smart meters and will eliminate the burden of yet another unfair fee for customers.

CEP Testimony

16