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Paul Street, 16th Floor Baltimore, Maryland 21202 April 3, 2012 Dear Commissioners: My comment focuses on five key issues that I believe are not being given adequate or honest attention by the utilities: 1) privacy issues, 2) interference with medical devices, 3) interference with ground fault circuit interrupter (GFCI) safety sockets, 4) national security issues, 5) hacking issues. Included are a small sampling of links to documents and web sites that support the main points raised in my comments. 1) Privacy Smart Meters, regardless of whether they use a wireless or fiber optic approach, will invade our privacy. In the first phase of the smart meter deployment, the meters will just capture overall energy use all day long. In the second phase, as people replace their current appliances with 'smart' appliances, the smart meters will communicate with all 'smart' appliances, creating a mesh home area network. Even in the first phase, the smart meters will capture and send to BGE a great deal of personal data. Anyone with access to the Smart Meter data could tell the following: o o o o o o When people are asleep or awake When people are home or away Whether they are running a small business in the house How many people are in the home at anyone time If the home contains expensive electronic equipment (e.g., plasma TV's) Whether the home's alarm system is on
The police in Ohio and Texas have already obtained smart meter data from the utilities without a warrant to verify the alibis of criminal defendants. This has serious 4th amendment constitutional implications that have not yet been litigated. Once the home area networks becomes common, the appliance use data will be worth a fortune to marketers. For example, the Smart Meter data can provide information on what type of oven a customer has, how old it is and how often it is used. That would allow oven manufacturers to target their marketing to those families with older ovens. Smart Meters will capture usage data from any medical device with a smart chip, and send it on to the utility. While this sounds like a clear violation of the Health Insurance Portability and Accountability Act (HIP AA), the utility or any marketer the utility sells the data to, are not covered by HIP AA. HIPP A only requires health care providers and
2) Interference with Medical Devices In regard to interference with medical devices, the FDA website warns that radiofrequency electromagnetic radiation can interfere with them. This is the type of radiation emitted by Smart Meters. While people can always shut off the source of the radiation if it is from a microwave oven, cell phone, WIFI or cordless phone, they will not be able to shut off the Smart Meter which operates 2417. The types medical devices at risk are: pacemakers, deep brain stimulators used in treating Parkinson's disease, ventilators, pain pumps and wireless insulin pumps. The FDA website is: http://www .fda. gov lRadiationEmittingProductslRadiationEmittingProductsandProcedureslHomeBusinessandEntertain ment/CellPhones/ucm 116311.htm
Nationally renowned Smart Meter expert Cindy Sage, of Sage Associates, poses the following question, which, along with other questions she asks can be seen at: http://sagereports.com/smart-meter-rfl?page id=188
What study has been done for people with metal implants who require protection under Americans with Disabilities Act? What is known about how metal implants can intensity RF, heat tissue and result in adverse effects below RF levels allowed for the general public. What is known about electromagnetic interference (EMI) from spurious RF sources in the environment (RFID scanners, cell towers, security gates, wireless security systems, wireless communication devices and routers, wireless smart meters, etc.) ? She goes on to explain that there are more than 20 million people in the US who need special protection against such exposures that may endanger them. High peak power bursts ofRF may disable electronics in some critical care and medical implants. We already have reports of wireless devices disabling deep brain stimulators in Parkinson's patients and there is published literature on malfunctions with critical care equipment. Finally she points out that in view of the rapid deployment of smart meters around the country, and the relative lack of public information on their radiofrequency (RF) emission profiles and public exposures, there is a crucial need to provide independent technical information. As stated so succinctly by Cindy Sage, there is very little solid information on which decision-makers and the public can make informed decisions about whether smart meters, are in fact, an acceptable new RF exposure, in combination with pre-existing RF exposures.
3) Interference with Ground Fault Circuit Interrupter
(GFCI) Safety Sockets
The electric industry designed special sockets that add an extra level of safety where water might come in contact with the socket: bathrooms, kitchens, decks and outdoor outlets. The radio frequency electromagnetic radiation has interfered with these sockets such that they did not trip when they were supposed to. This has apparently resulted in a number of serious fires in California and Texas. Below is a link to a website that collects reports of fires linked to Smart Meters from the United States, Australia and Canada. http:// emfsafetynetwork. org/?page id= 1280 Shockingly, these Smart Meters are not listed by either United Laboratories (UL), or American National Standards Institute (ANSI). It is not clear if our standard homeowners' insurance will protect us if the fires are caused by a utility's smart meters. One insurance company said it would cover the damage from a fire and subrogate the claim against the utility, but another insurance company suggested the homeowner would need to directly sue the utility if the Smart Meter was the culprit. Central Maine Power has set up a special unit for their smart meter program because of electrical interferences and have settled claims. http://www.dslreports.com!shownewslPower -Utility- Smart -Meters-Causing- RouterInterference-117120
4) National Security There are several companies in the United States that will be producing smart meters, but many of the components will be manufactured outside of the United States. This is a golden opportunity for unfriendly powers and/or terrorists to put malware on the components that can be activated remotely to bring down power grids. Intelligence officials recently briefed Congress on the risks of cyber terrorism. Attacks on the power grid is one of their main concerns now. China is rapidly expanding its military, but it knows it cannot beat us militarily. But bringing down the power grid would enhance their chances of winning such a contest immensely. The grid we share with Washington, DC would obviously be a very high priority target. Department of Energy's (DOE) Inspector General recent1y took DOE to task for ignoring the cyber terrorism issues in rushing to create the smart grid with smart meters. This report is entitled: The Department's Management of the Smart Grid Investment Grant Program, OASRA-12-04. In addition, former CIA Director James Woolsey criticized the whole concept of a smart grid because it makes this country vulnerable. The following is a link to a short interview with Mr. Woolsey: http://www.energynow.com/video/20 11/08/1 O/preview-mix -llImes- woolsey See also the following link regarding cyber security issues: http://smartgrid.testing-blog. com/tag! cybersecurityl
5. Hacking Issues Some smart meter designs can be easily hacked into as they use antiquated software that lends itself to hacking. Wireless transmission of data is particularly vulnerable to hacking. Hackers have already transferred energy use onto unsuspecting customers. Hackers have also managed to maliciously turned off electricity to homes. Pacific Gas & Electric, which has installed a large number of smart meters, has admitted that hacking is going on, but refuses to divulge the extent of the problem. As mentioned in the privacy issues discussion, there is an outstanding piece of research on this issue by the Congressional Research Service entitled, Smart Meter Data: Privacy and Cyber security. This report addresses the hacking issues. That report can be found on the following website: h.tlp-: Ilwww.fas. org!sgpl crs/misc/R 4233 8..J2df Respectfully submitted,
Mr. Moshe Miller
Certificate of Service I, Rebecca Hanna-Diener, will hand deliver an original and 17 copies of this Comment by Moshe Miller, regarding Case No. 9207 and Case No. 9208; on Wednesday, April 4, 2012 to Mr. David Collins, Executive Secretary, Maryland Public Service Commission, William Donald Schaefer Tower, 16th Floor, 6 St Paul Street, 16th floor, Baltimore, Maryland 21202
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