RESPONSE TO “BCUC’s Staff Report on Smart Meter Fire Safety Concerns”

KEY:  Highlighted text is from Sharon Noble  Non-highlighted text is the draft report as written by BCUC staff.

___________________________________________________________________________

Segment #9

In Segment #9 of the response to the BCUC draft report, BCUC finally admits it is responsible for public safety. This after years of denying it could do anything because of the Clean Energy Act and Direction 4.  Note under “Standards and Meter Compatibility” questions about certification and safety testing had been asked over and over again in many letters to both BC Hydro and the BCUC, concerns were raised, yet there has been no oversight. And BCUC consistently failed to do its job as defined in the BC Utilities Commission Act – protect the public.

I still have received no response to my complaint or my request to be told when one might be forthcoming. What is going on? When asked about the possible liability by each and every agency and all key personnel for harmful negligence, no response was forthcoming.

Sharon Noble

= = =

Utilities  (continued)

In 2013, the Provincial Government issued Special Direction 4 (Order In Counsel No. 391) to give customers an option to opt out of the smart meter program. The directive also limits the BCUC’s mandate with respect to BC Hydro’s smart meter program stating that the Commission must not “directly or indirectly prevent [BC Hydro] from installing, operating or providing services in respect of legacy meter, smart meters and radio-off meters.” Therefore, BCUC has oversight responsibility of smart meters as it relates to public safety but does not have the authority to prevent BC Hydro from installing or operating smart meters. This limitation in BCUC’s mandate does not apply to FortisBC meters.

*        What, if any,  penalty does BCUC suffer if it fails to take responsibility for public safety in regard to the smart meter?

*        If BCUC has evidence that smart meters are not safe, that incidents have occurred that put lives and property at risk, what can BCUC do to protect the public as is its responsibility under the Utilities Commission Act?

*        Who can prevent BC Hydro from forcing people to have fire hazards on their homes if both BCUC and the government refuse to take this action?

Comment:

During correspondence over the past three years, the BCUC had rejected several written requests to examine smart meter safety issues. The BC Hydro smart meter implementation was therefore carried out without supervision or monitoring by the BCUC.         

On what date did the BCUC change its focus to include smart meter safety issues?  It seems to date from July 2015, since prior to that date, the BCUC refused to be involved in safety issues to do with the smart meter implementation program, See BCUC correspondences dated around 8th July 2013, below in the Section: Standards and Meter Compatibility.         

BCUC’s own statement: 21 October 2013, Quote:” As previously stated, Section 7 of the Clean Energy Act exempts BC Hydro’s Smart Metering Program from Commission regulation under certain sections of the Utilities Commission Act – the Act that establishes the Commission’s authority. Subsection 7(3) further states, “The commission must not exercise a power under the Utilities Commission Act in a way that would directly or indirectly prevent the authority from doing anything referred to in subsection (1).” In other words, the Commission cannot take any action that would prevent BC Hydro from implementing the smart metering program.  As a result, the Commission has not been involved in the planning or implementation of the program.” Unquote.

And, October 31, 2013: BCUC Letter: Quote: “In reviewing BC Hydro’s Application (Approval of Charges for Smart Meter Program), the Commission’s hearing is limited in scope to the recovery of costs of providing services to customers in relation to their choice of meters. Direction No.4, section 4 establishes limits on the Commission’s powers to review the Application.”Unquote. 

Standards and Meter Compatibility

Concerns have been raised that existing meter bases were not designed for modern electric “smart” meters.   The question of compatibility is applicable to manufacturers of both meter sockets and electric meters regardless of the type of meter. For example, existing meters that no longer meet accuracy testing are typically replaced by newer digital or smart meters as the existing vintage may no longer be supported by the manufacturer or procured by the utility. Standards are developed and maintained for this purpose so that for example the receptacle for your home wall outlet will be compatible with the devices you purchase to plug into the outlet now and many years from now until an entirely new standard is created. In the case of electrical meters, there are a number of standards used in North America specific to meter sockets and meters. Some standards cover the performance and accuracy of meters and others cover the physical aspects.

Standard making bodies involved in meter socket and meter standards in North America include the American National Standards Institute (ANSI) and the Canadian Standards Association (CSA). Other testing and certification bodies represent insurers such as Underwriters Laboratory (UL) or Factory Mutual (FM) may have both US and Canadian standard versions (UL and ULC).

Comment:

Why are these Meter Standards listed as “Applicable Standards” when the BCUC state in this Report (Page 3, under the BC Safety Authority and Page 3, under Utilities)  that BC Hydro is exempt from Electrical Safety Regulation. According to this report, we have no way of verifying if the meters actually are Certified to the CSA CAN3-C17, and according to BCUC there is not a requirement for that under the BC Safety Regulations. BC Hydro have repeatedly stated that their equipment does not need to be certified to CSA Standards.

Comment:

BC Hydro letter dated 31 January, 2014,  Quote:                
“I am writing in response to the above-noted request for records under the Act. BC Hydro has reviewed its files and has found no records responsive to your request. Electricity meters are BC Hydro-owned devices and are not subject to the certifications mentioned in your request and, consequently, BC Hydro has no certification documentation of the type you requested.” Unquote.                

Extracts below are from the Letter to BCUC dated 27 February 2014 requesting that Safety be part of the BCUC mandate:                
QUOTE: ABSENCE OF METER TESTING AND CERTIFICATION – Safety, BC Hydro Quote: “I am writing in response to the above-noted request for records under the Act. BC Hydro has reviewed its files and has found no records responsive to your request. Electricity meters are BC Hydro-owned devices and are not subject to the certifications mentioned in your request and, consequently, BC Hydro has no certification documentation of the type you requested.” Unquote.

NON-CERTIFIED METERS ARE BEING INSTALLED INTO CSA CERTIFIED METER BASES – Safety.  The combination of the meter and its existing base is not certified by CSA for disconnecting or connecting power, so the change-out needs to be carried out with the power switched off at the BC Hydro source (power pole, transformer fuse High Voltage disconnect etc). Whether BC Hydro has always used this “yank-out” method over the years during change-outs raises concerns about miss-use, wear & tear, contributing to failures. Note that there is not a single independent central system in place to report meter problems, so that when contacted, the Insurers, Municipalities, IBEW, Fire Marshals and Safety Authorities advised that they do not have the information to prepare them for the extent of this serious issue.                

ABSENCE OF OVERSIGHT ON BC HYDRO – Safety. In the absence of oversight on BC Hydro by any BC Authority or Ministry under the Hydro and Power Authority Act, the B.C. Electrical Safety Regulations 100/2004, British Columbia Safety Authority (BCSA), British Columbia Utilities Commission (BCUC), B.C. Chief Medical Officer, Lieutenant Governor, and the Electricity and Gas Inspection Act, we have to assume that each organization and its key personnel can be held liable for lack of due diligence and any harm that is occurring to consumers, whether due to safety issues, inaccurate and fraudulent billing, health issues, and the unjust and unreasonable cost of the entire system.

The writer has previously written to BCUC more than once to point out that the Safety for consumers should never be removed from any review by BCUC.                

These issues have been brought to the attention of BC Hydro, the British Columbia Utilities Commission and a number of other BC Authorities over the past two years, however it appears that none of these issues has been dealt with in a professional manner, nor have they been resolved nor documented in an effective and satisfactory way.                

End of letter to BCUC