2018-03-23 New Mexico PUC hearings indicate testing responsibility left with ITRON with no or little independent oversight or confirmation

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1)    Below in Letters is a very important one from someone who is very knowledgeable to those who are ultimately responsible for safeguarding the public and electrical safety. It was sent in hopes that these people would understand the shortcomings to do with smeter safety, testing and regulatory dysfunction that are identified. The concerns are backed with testimony from a hearing conducted by the New Mexico PUC (https://stopsmartmetersbc.com/wp-content/uploads/2018/03/Citizens-for-Fair-Rates-the-Environments-Brief-in-Chief-Thomas-Manning-PNM-Hearings-Case-No.-15-00312-UT-December-05-2017.pdf) regarding imposition of smeters on the public.

(click on photos to enlarge)

As we have seen in responses from BCUC and BC Hydro, significant design problems are overlooked or potential problems are not tested to ensure they will not cause fires are not tested to ensure they will not cause fires. We are to believe and accept that ITRON is doing the testing honestly and well. Foxàhenhouse. And where is the utility company in this? Where is its responsibility to ensure its equipment is safe?

2)    The Dark Side of the Internet of Things and 5G presents how technology is being used today to gather data and how this will be expanded with 5G (5th Generation Technology).   I watched only the first 20 minutes or so. Seems especially relevant because of the recent disclosures about Facebook’s use of personal data.

Exposing The Dark Side of #IoT & #5G

https://www.youtube.com/watch?v=AGz1Cw5hxQg    (66 minutes with English subtitles)

3)    The IoT makes everything vulnerable from cars to ATM machines to pacemakers.

It Only Takes Seconds to Hack an ATM… Are Our Cars Just as Vulnerable?

The More Complex the System the More Vulnerable it is to Attack and Human Error

Jack also hacked implantable defibrillators. He figured out how to control these pacemaker-like devices remotely and deliver an 830-volt shock to a patient’s heart. The attack showed up in the television series Homeland, when terrorists hacked the fictional vice president’s pacemaker to assassinate him. Critics called the plot far-fetched. But Jack thought the show actually made the attack seem too difficult. Others took the threat seriously, too. Years before Homeland aired, Vice President Dick Cheney had his cardiologist disable the wireless functionality in Cheney’s implanted device to avoid just such an attack…

Several manufacturers, for example, already make “smart” washers and dryers that connect wirelessly to the internet. These appliances do clever things, like automatically reordering detergent and monitoring the cost of electricity to run only when rates are low. So far, so good. But think about the risks. If our smart dryer has a security flaw, hackers might be able to access it remotely, reprogram the software to overheat the motor, and cause a fire. If even just a thousand homes in a medium-size city had a vulnerable dryer, a hacker could wreak havoc.”

https://lithub.com/it-just-takes-seconds-to-hack-an-atm-so-how-long-for-a-self-driving-car/

[(video 05:02) Hackers Remotely Kill a Jeep on the Highway—With Me in It by Andy Greenberg – Wired – July 21, 2015:
http://www.wired.com/2015/07/hackers-remotely-kill-jeep-highway/]

4)    There are many reasons why Wi-Fi should not be in schools, so why are the schools in BC insisting that all students be exposed to this microwave radiation?

https://www.activistpost.com/wp-content/uploads/2018/01/Meme-wired-internet.jpg

Chloroform, Engine Exhaust, Lead, And Wireless (WiFi) Radiation Are All “Possibly Carcinogenic” — Schools Should Provide Wired Internet

Decades of scientific research on exposure to cell phone radiation, wireless (WiFi) radiation, and electrical pollution (Electrosmog) [http://www.nbcnews.com/id/34509513/ns/health-cancer/t/electrosmog-harming-our-health/] has already proven that it can worsen pre-existing conditions even if didn’t cause them.

There are many symptoms and health conditions attributed to exposure to cell phone and wireless (WiFi) radiation and electrical pollution (Electrosmog) besides increased possible cancer risk.  Some will be more affected than others.  This is true of exposure to chloroform, engine exhaust, and lead as well.

U.S. federal safety standards and guidelines were established over 20 years ago.  We are all exposed to more cell phone and wireless (WiFi) radiation and electrical pollution (Electrosmog) emitting sources than when these standards and guidelines than we were created.

– http://ethics.harvard.edu/files/center-for-ethics/files/capturedagency_alster.pdf

20+ year old laws protect these standards and guidelines – not science…

Utility companies are NOT required to provide customers with written guidelines when they install wireless or digital “smart” meters.  This may prove problematic, especially for those who spend extended periods of time within close proximity to a utility “Smart Meter” or multiple “Smart Meters”.

Like cell phones and other wireless and electronic devicesutility “smart” meters have also been known to malfunction, catch fire, and explode.

Many believe that these utility “Smart” Meters exceed current federal safety standards which apparently don’t apply to children or pregnant women anyway.

Some scientists insist there is enough research that proves wireless (WiFi) radiation should be classified as a Group A Carcinogen.  Some scientists use current laws to defend the safety of both wireless (WiFi) radiation emitting technology and tobacco products.

https://www.activistpost.com/2018/03/wireless-wifi-radiation-possibly-carcinogenic.html

Letters:

 

– https://stopsmartmetersbc.com/wp-content/uploads/2018/03/Citizens-for-Fair-Rates-the-Environments-Brief-in-Chief-Thomas-Manning-PNM-Hearings-Case-No.-15-00312-UT-December-05-2017.pdf

From: X
To: env.minister@gov.sk.cammarsh@saskpower.comEMPR.Minister@gov.bc.caAEST.Minister@gov.bc.capremier@gov.bc.ca
Date: Mar. 19, 2018

Subject: Parties responsible for electrical safety, the performance of Corporations, including the Utilities, the supervision of Regulators and the licensing of Engineers

Dustin Duncan <env.minister@gov.sk.ca>
Minister responsible for SaskPower
Room 345, Legislative Building,
2405 Legislative Drive,
Regina, SK
S4S 0B3

Mike Marsh <mmarsh@saskpower.com>
President and Chief Executive Officer SaskPower,
2025 Victoria Avenue,
Regina, SK
S4P 0S1

BC Ministry of Energy, Mines and Petroleum Resources
Michelle Mungall <EMPR.Minister@gov.bc.ca>

BC Ministry of Advanced Education, Skills and Training (EGBC)
Melanie Mark <AEST.Minister@gov.bc.ca>

John Horgan <premier@gov.bc.ca>

Sirs/Madam,

This important letter is addressed to the Parties responsible for electrical safety, the performance of Corporations, including the Utilities, the supervision of Regulators and the licensing of Engineers.

I trust that the persons reading this letter will take prompt and effective action to address the shortcomings described herein and in the attached documenthttps://stopsmartmetersbc.com/wp-content/uploads/2018/03/Citizens-for-Fair-Rates-the-Environments-Brief-in-Chief-Thomas-Manning-PNM-Hearings-Case-No.-15-00312-UT-December-05-2017.pdf

I read with interest the recent reports in the Media about the attempts by SaskPower to find the best design for smart meters, and to identify the appropriate testing Standards and procedures.

Having followed the implementation of smart meters for several years, I have concerns related to the AMI including the regulation of the Utilities and the testing of digital meters.

The Public Utility Commission’s Hearings now underway in New Mexico identify many identical issues pertaining to the AMI in British Columbia. See the attached PDF file extract.

It appears that in many cases the Utility Commissions and the Power Utilities have relied upon the meter Manufacturer to verify the safety of the AMI by having the meter Manufacturer document their design of the meters, to conduct the tests and to verify the test results.

In addition, when the overall power system and AMI system are examined, it appears that there are often misunderstood and missing critical areas of responsibility, as is being uncovered in New Mexico.

These missing critical areas of responsibility have been highlighted more recently during the Hearings in New Mexico and by numerous correspondences from this writer to the Regulators, to the Professional Associations and to Government.

That there has been no adequate responses to this writer’s correspondences proves how necessary are the type of Public Hearings now occurring in New Mexico, which should have happened in Canada.

There is an urgent need to provide a Canada-wide consistency to assure Public safety of the AMI systems including identifying any required changes to:

1. Utility Company Engineering Practices, including the stamping and the signing of engineering work, regardless of whether the work is in the Utility’s scope or the Meter Manufacturer’s scope. Detailed discussion is needed with each Provincial Engineering Association to clarify and to confirm the Utility’s responsibilities and accountability. Where no regulations exist (as in B.C.) governing the engineering work of corporations, immediate action is needed.

2. How the delegation of responsibility to Manufacturers is properly structured,

3. Staff technical capabilities at the Utilities Commissions when reviewing the Utilities’ complex applications,

4. Utility power systems’ protective device applications applying to digital devices,

5. Regulation of the Utilities as both a Public Service and as a Corporation conducting Engineering, as apparently is common in other jurisdictions.

In response to Freedom of Information requests from the Public, the Utilities have cited privacy concerns that prevented them from providing information about the protective device applications and about the testing and certification of meters, disconnect switches and devices.

There is a need to apply consistent Engineering expertise both by the purchaser and by the Utilities’ Commissions prior to and during the implementation of digital meters.

Not only should this require proper engineering examination of the impact of digital devices upon the Utility electrical power system, but also the independent meter testing, including functional testing of the disconnect switch using the most effective Standards and real-life conditions.

This has been identified by the writer and also in the New Mexico hearings as an area lacking adequate attention. There appears to be no acknowledgment or action by the Utilities that the proper engineering studies and possibly specific changes to the power system are required.

In one blatant example in New Mexico, the Utility’s spokesperson completely misunderstood the Utility’s responsibility for such studies.

Where appropriate Standards and Procedures do not meet the needs for the mass implementation of millions of meters, then much more effort must be made to assemble effective procedures, designs and testing methods to guarantee safe trouble-free service for many years.

The “Responsible Professionals” who certify and who “sign-off” on the safety of the AMI systems, the meter designs and the device testing must be able to demonstrate to the Regulators and to the Public that the content, methodology and test procedures are effective and that the pass/fail criteria are auditable.

Some of the evidence uncovered in the New Mexico Hearings points to an inadequacy of the parties to prove that their equipment has been properly and adequately tested and that the equipment is safe.

It appears that some Utility Commissions continue to accept the Utility’s data at face value and have not exercised adequate scrutiny in a technical sense to verify the safety of the AMI. These Regulators must have the necessary expertise to evaluate and to verify the accuracy and correctness of the technical content of each of the Utility’s application.

Utility Responsibilities:

With the introduction of millions of digital meters in place of analogue meters, an engineering examination of the power system protection of electrical services would seem not only appropriate but necessary and urgent.

Due to the fact that millions of meters are being changed-out, sometimes more than once, it would seem statistically obvious that problems will occur and therefore the Utility’s electrical circuit protection afforded by the high-voltage fuses is critical to detect and to isolate a failure before it develops into a life- and property-threatening event. Note that the previous Government changed the BC Electrical Safety Act to allow non-electricians to work on electrical services and do meter change-outs.

Note that a low-voltage phase-to-ground arcing fault at the customers’ service is more severe than a phase-to-phase fault, due to its intermittent but highly destructive nature. Moreover it is difficult if not impossible for the Utility’s existing primary protective device to detect and clear a destructive low-voltage arcing fault in adequate time to limit severe damage to the meter, its base and to the residence. After the introduction of millions of smart meters, this occurrence is more frequent than before and has dramatic consequences.

It remains the Utility engineers’ responsibility to apply due diligence to their work to ensure that not only are Standards adhered to but that their designs are adequate for the purpose, which may require the addition of engineering measures outside of established Standards.

There appears to be an over-reliance on minimal diligence as when many parties state that the Standards have been met when clearly, as in New Mexico, the parties have problems proving that fact. They also do not seem to subscribe to that Professional requirement that these critical systems must satisfy the “Fit for Purpose” edict as being paramount for the protection of the Public.

This critical point about complete and responsible engineering measures appears to be missing from much of the processes witnessed to date.

In some B.C. electrical incidents, there appears to be an absence of the old-style of electrical surge protection still used in analogue meters. Media articles describe voltage surges and transients that resulted in serious damage to meters and to homes (Example: Summerland, B.C.).

Tests for the meter’s ability to withstand power system voltage transients need to be realistically designed to represent real-World events, to reproduce, for example, the Summerland, B.C. over-voltage incident which destroyed many smart meters and damaged homes, and left homeowners alone to deal with damaged wiring and many failed appliances. It appears that analogue meters withstood this event without damage far better than digital meters.

The Utility must be able to provide independent documented evidence to the Regulators and to the Public that the electrical service installations are safe, and prove that when an electrical failure occurs, as is more common during and since the mass implementation of digital meters, that the Utilities’ protective device operates effectively to limit the risk to the residents and damage to homes.

Signed:
X

 

Sharon Noble
Director, Coalition to Stop Smart Meters

The absence of evidence of hazard is not proof of safety”
~ says Dr. Devra Davis

www.facebook.com/Coalitiontostopsmartmeters

Smart Meters, Cell Towers, Smart Phones, 5G and all things that radiate RF Radiation