Papazian & Mead, PLC
2141 E. Highland Avenue, Suite 105
Phoenix, AZ 85016
Frank R. Mead
Attorney-at-Law
P: (602) 620-1449
F: (602) 606-8300
April 25, 2012
By US Mail
Arizona Corporation Commission
Docket Control
1200 W. Washington St.
Phoenix, Arizona 85007
Docket
# E-00000C-11-0328 – Smart Meters
Re: How often wireless smart meters
actually transmit
Dear Commissioners:
During the March 23rd hearing, one Arizona Utility stated that it only
receives transmissions 14 times a day from each of their smart meters. Another
Utility stated that they receive data every 15 minutes. These are low-end
numbers, and not representative of the current technologies. As evidenced by the September 8, 2011 hearing
when Tucson Electric/Unisource
disclosed that their AMR meters transmit every 30 seconds, or 2880 times a day.
There have been complaints in other states that utilities there did not
fully disclose how often their
meters actually transmit. Some utilities were apparently only stating how
often they read their meters, but omitted
other types of transmissions. From a human health perspective, the informational content of a wireless
transmission is irrelevant. It is the
actual act of transmission that matters. Otherwise, there is no distinction.
Following these complaints, on October 18, 2011 Administrative Law Judge
Yip-Kikugawa directed the three largest California utilities to make specific
and detailed disclosures. The response from Pacific Gas & Electric is
enclosed.
In Table 2-1 of the response, it is stated that each meter is read six
times a day. However, the total number of transmissions from each meter is
typically 10,000 a day, or once
every 8.6 seconds.
The PG&E system is a Òmesh networkÓ where some of the meters act as
relay stations. These
meters can transmit much more often. According to PG&EÕs Table 2-1 (right side), they may transmit as often as
190,000 times a day or about twice a second. It is not possible to know which
of the meters serve as relays, and it may change over time which of them does. Mesh networks are state
of the art and are being deployed by many
utilities, including utilities in Arizona.
Therefore, the public health is best served by limiting these
transmissions as much as possible,
especially since most, if not all, of the desired goals can be accomplished
with much less.
However, we must stress that limiting the transmissions is not a viable
alternative to a medical
opt-out for people with electrical hypersensitivities. People with EHS must be allowed to have a non-communicating electromechanical meter.
There is no other choice.
Submitted on behalf of:
Safer Utilities Network
P.O. Box 1523
Snowflake AZ 85937
Enclosed (1): Pacific Gas and Electric CompanyÕs response to
Administrative Law
JudgeÕs October 18, 2011 Ruling Directing it to File Clarifying Radio
Frequency
Information (pages 1 and 5 only)
