This document can be downloaded at http://www.scribd.com/doc/178361443/Smartmeter-fees-VsOpting-Out-Who-really-pays Jeffrey T.

Ono, Director Department of Commerce and Consumer Affairs DCCA Division of Consumer Advocacy PO Box 541 Honolulu, HI 96809 808-586-2800 consumeradvocate@dcca.hawaii.gov www.cca.hawaii.gov Public Utilities Commission (PUC) 465 South King St., Room 103 Honolulu, HI 96813 808-586-2020 hawaii.puc@hawaii.gov October 23, 2013 Re: Kaua'i Island Utility Coop's (KIUC) application for rate tariff change (Application # 2013-03/filed 10/3/13). Dear PUC, DCCA and KIUC, I write in reference to KIUCs rate tariff request to the PUC filed on 10/3/13. I object to the request of a set up fee and a monthly charge for KIUC members who do not have a wireless smartmeter. KIUC is a Coop and costs are shared by all members. All members paid for smartmeters whether they have/want one and all members should pay for those who opt out. KIUC members are circulating a petition for a special membership meeting where this request will be voted on. Any action by the PUC should be held until this meeting occurs. In addition, KIUC, in five years from August 2008 2013, went from 157 to 147 employees while the payroll went from $12,235,317 to $15,805,665. This is the time period where meter readers were supposedly let go and there should be a payroll deduction. Where are the savings members were promised from firing meter readers? (See - http://website.kiuc.coop/content/financials) I am one of the majority of residents of Kaua'i who are excluded membership to the KIUC Coop as only the people who have an account with KIUC are considered members. While I am not a member I do live in a home that is served by KIUCs electrical grid and am effected by their actions. I too must pay more for my electricity usage when they increase their rates. We are all effected by their poor management and decisions. Members were not consulted or polled as to whether they wanted smartmeters and KIUC has not done a cost benefit analysis of the rollout. Why wasn't this required?

The world is in the process of updating our electrical grid. There are many benefits to us all when utilities upgrade old infrastructure and increase efficiency, however the smartmeter rollout has not been shown to have a cost benefit. It is a fact that digital wireless smartmeters use more energy than the analog electromechanical meters they replace. It is a fact that smartmeters do not save any energy at all. It is a fact that electromechanical meters last over 20 years and that there is a great likelihood that smartmeters will have to be upgraded or replaced within 5 years. Smartmeters have been rolled out by governments as a way to stimulate the economy and they cost utility users more than they will ever save. According to Frost & Sullivan energy analyst Neha Vikash, Germanys Economy Ministry... concluded that smart meters would be too expensive to deliver economic benefits... Germany has 48 million meters, with around 90 per cent being electromechanical which can have a working life of anywhere from 20-40 years. ...replacing them over a period of five-to-seven years would generate an estimated 6bn ($8bn) revenues for smart meter and communications manufacturers... This amount does not include the estimated 7.5bn that would be spent on supporting infrastructure, project management and installation. (See - http://www.powerengineeringint.com/articles/2013/09/billions-of-smart-grid-investmentthreatened-by-germany-meter-opposition.html) In March 2007, the Iowa Utilities Board decided not to adopt PURPA Standard 14 (Time-Based Metering and Communications) as enacted in EPACT 2005. The Board determined that mandating deployment of smart meters was not cost-beneficial. Furthermore, the Board decided that it is difficult to regulate a single standard for advanced metering, writing: One size apparently does not fit all. (See - http://www.sgiclearinghouse.org/node/1707) My household is one of the 3,000+ households that have opted out of a smartmeter. There are valid and legally defensible reasons to opt out of a smartmeter. KIUC promises on their website that they will not sell usage data, but this is a policy that can change. Other utilities are already doing this. In addition, smart meters can be hacked by the police and by criminals. These are invasions of privacy. The Supreme Court has ruled that the use of thermal imaging of a home and that the attachment of GPS devices to track people and cars is a violation of the 4th Amendment. Smartmeters which track usage of appliances is of a similar nature and may well find the courts reaching a similar verdict. See http://www.computerworld.com/s/article/9233265/Smart_meters_not_so_clever_about_privacy_researc hers_find?pageNumber=1 and http://coto2.wordpress.com/2012/04/13/hacking-expert-david-chalkjoins-urgent-call-to-halt-smart-grid/) The misnamed Smart Grid is open to being hacked. Having a wireless system creates vulnerabilities throughout the grid. Former head of the CIA, James Woolsey, has come right out and said it is a Stupid Grid.

(See - http://www.energynow.com/video/2011/08/10/preview-mix-james-woolsey) People are already hacking their own smart meters and stealing electricity. The FBI reports that thievery may costs utilities $400 million a year. (See - http://www.networkworld.com/community/blog/fbi-warns-smart-meter-hacking-may-costutilities-400-million-year) And yes maintaining a healthy environment in our homes is a right as there is no enjoyment of a home if it becomes so toxic that residents can no longer live there. Thousands of studies show evidence of harm from microwave exposure at the levels emitted by smart meters. The International Agency for Research on Cancer determined that this type of radiation is a Class 2B possible carcinogen - the same category as lead, DDT and gasoline. We do not place gas stations in neighborhoods or store gasoline in our bedrooms, but many people have been forced to have a cancer agent/smartmeter placed on their bedroom walls. The BioInitiative Report 2012 reviewed 1,800 studies from the five previous years and determined that that the Federal Communications Commission (FCC) exposure guidelines to radio frequency radiation (RFR) emitted by wireless devices are not protective. The FCC allows 1,000 microwatts per square centimeter (uW.cm2). Russia, China, Italy, Switzerland and Monaco allow 10 uW/cm2. The BioIntitiative finding is that RFR levels should be kept below .003 uW/cm2. The IEEE Committee on Man and Radar statement on smartmeters reported that one smartmeter could be as high as 100 uW/cm2. See (http://www.iarc.fr/en/media-centre/pr/2011/pdfs/pr208_E.pdf, www.bioinitiative.org and http://ewh.ieee.org/soc/embs/comar/COMAR%20Smart%20Meter%20TIS%20(9-25-2013).pdf) For these reasons the PUC should deny KIUCs tariff request. Regardless, any action by the PUC on KIUCs tariff request should be delayed until the KIUC member petition process is completed and a special membership meeting is held to vote on the Board's action. Submitted by: Angela Flynn PO Box 1439 Kilauea, HI 96754 808-822-3982 angelaflynn80@msn.com