📬 No AMI

Al Carr, Maryland House of Delegates, representing Maryland's District 18

Thank you for allowing me to submit comments on WSSC Water’s proposed six-year (Fiscal Years 2022-2027) Capital Improvements Program (CIP).

I ask commissioners to carefully evaluate the proposed $100M Advanced Metering Infrastructure project also known as smart meters. I am not referring to potential health, privacy or jobs impacts but specifically the financial impacts of smart meters.

Regarding the financial impacts of smart meters, there are unanswered questions that commissioners need to resolve:

• 1. Do the benefits of smart meters outweigh the costs?

  2. Will implementation of smart meters result in higher or lower water bills?

  3. What are the risks? Implementation of smart meters will put WSSC Water into the business of collecting massive amounts of customer data. Is this WSSC Water’s core competency? Is there a potential for IT cost overruns as occurred on the billing system replacement?

I also believe that commissioners need to seek out objective, unbiased information about smart meters.

Smart meters were first approved in the CIP in 2012 under a different General Manager. Their justification and cost estimate is based on a study that was performed in 2011 and has not been updated since other than adjusting for inflation.

I hope you will also consider the experiences of nearby utilities. When I reached out to the General Manager of Fairfax Water in December 2018, he told me that Fairfax Water had rejected AMI smart meters as too costly. For many customers, Fairfax Water’s rates are half of WSSC Water’s rates.

I also hope that commissioners will ask staff to present you with a range of options to improve meter reading. AMI is currently presented as an all-or-nothing, but there are other options. The City of Rockville was able to obtain many of the promised benefits of AMI smart meters but at a lower cost by using a system of drive by AMR meters. With AMR, Rockville was able to reduce labor costs and eliminate estimated readings but without the expense of a wireless data network and extensive IT infrastructure required by AMI. Another feature of Rockville’s AMR system is that an opt out policy is not applicable because drive-by AMR meters configured for “wake up” operation do not continuously capture and transmit detailed customer usage information and lack the consumer privacy and health concerns raised by AMI that drive some customers to seek opt outs. Rockville has addressed unbilled water concerns by focusing on replacing older and wrongly-sized large meters.

If you decide to move forward with AMI smart meters, please adopt an opt out policy. That is the policy of the State of Maryland as established by the Maryland Public Service Commission when they approved AMI smart meters for most of the investor- owned electric utilities.

Speaking of the PSC, there is testimony on their record about how some promised benefits of AMI smart meters did not materialize at electric utilities.

I appreciate your efforts to provide safe and reliable water, life’s most precious resource, and return clean water to our environment, all in an ethical, sustainable, and financially responsible manner.

Sincerely,

Delegate Al Carr

Mary Rooker:

Calling for Fiscal and Environmental Responsibility

My name is Mary Rooker, WSSC customer. I ask that you use the AMR drive-by meter system because, unlike the AMI, AMR protects privacy, health, and the environment.

Four states and our own regional water utilities have found that AMI is not cost effective and is a bad investment, citing exorbitant costs and lack of customer benefit. Other utilities who deployed "smart" meters ended up RAISING rates. Fairfax Water rejected AMI smart meters as too costly back in December 2018. Their rates are half of WSSC's rates.

If you proceed with AMI smart meters despite the science and your own best financial interests, you must provide a no-cost opt-out. Your staff has counseled you to ignore the statewide opt-out policy of the Maryland Public Service Commission.

Forcing a penalty fee on those desiring to protect their family’s health violates WSSC’s ethical mission—it’s an act of environmental racism. This penalty is especially burdensome to those of us who can least afford it. I ask for your leadership to be an example to other utilities rather than repeating their mistakes.

The industry says that AMI smart meters are good for the environment because meter readers would not need to drive through the service area. Yet this aspect could be resolved by upgrading to electric vehicles or switching to quarterly readings.

Also, AMI smart meters will waste about 40% of the existing meters that are in perfect working order. Further waste is created in replacing the iron meter space tops, as iron interferes with radio frequency. AMI batteries appear to have a short shelf-life: the District of Columbia has had two wholesale meter replacements in the past ten years.

AMI meters also damage the environment due to their health impacts on pollinators and wildlife.

The industry is aware of the human health and safety risks—that's why they had Congress exempt the entire industry from federal regulation for wireless structures.

I specifically request:

1. a formal health impact assessment;
2. a formal Environmental Impact Statement; and
3. an update and Council review of the now-outdated 2011 consultant’s report.

Full disclosure: I’m also a member of the Montgomery County Green Party. Please either use the AMR drive-by system or, if you must use AMI metering, provide opt outs at no charge.

Thank you.

Theodora Scarato, Environmental Health Trust

US Resident Wins Housing Case Regarding “Smart” Water Meters: Mechanical Meter For Resident PLUS Neighbors

Court case regarding water meters - Not only was a resident provided a mechanical meter- after a court win- but in addition the neighbors of three adjacent properties also were made to switch to mechanical meters.

Furthermore NO charges- NO FEES- could be imposed for the switch. The Court verdict says that the Fair Housing Act prohibits discrimination based on disability.

Let WSSC Commissioner, Montgomery County officials and Prince George's officials know your views:
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