Dear WSSC "AMI is a financially unsound investment"

To: WSSC Commissioners and AMI Project Team                                                    BY EMAIL          

I attest and affirm that the following statements are true, accurate, and within my personal knowledge.

Do not move forward with the proposal to procure AMI smart meter contracts or projects.

Before I address the reasons why I’ll share a recent experience. While shopping for toilet paper, I came across flushable wipes. I quite enjoyed using flushable wipes; the packaging is nice, they’re portable, they work well, they’re convenient and some brands are advertised as “Totally Flushable. Totally Innocent.” They even explain that they use a patented SafeFlush Technology® so that wipes start to break down immediately after flushing. Yet, I did not purchase the wipes. Why? Because I’m aware of the damage they cause thanks to your information campaign, “Keep The Wipes Out of The Pipes!”

My two take-a-ways are these:

   1) Newer is not synonymous with better. Old-fashioned toilet paper gets the job done just fine.

2) Marketing gimmicks and false advertising are the name of the industry game. Wipes marketed as “flushable” technically pass requirements to be safe for sewage or septic systems yet water utilities around the world are dealing with the costly burdens of fatbergs.      

The flushable wipe campaign is akin to that of smart meters—inflated assurances of efficiency, reliability and safety that technically could be true, but in actuality are not -- I implore you not to buy the hype.

The states of New Mexico (2018), Massachusetts (2018), Kentucky (2018) and Virginia (2019) have all listed that their official reasons for rejecting smart meter proposals has been a) exorbitant costs; and b) lack of customer benefit. Unofficially, health effects from radiation emissions fueled much of their customer’s opposition. According to Nekabari Goka, as one public utility commissioner put it, “I hear a lot about enablement and potential in grid modernization proposals…however potential is not a benefit.”

A common argument promoting smart meters is the aging infrastructure. The current meters have lasted decades and are still operating well, whereas the life span of smart meters is a fraction of its analog counterpart. A research study sponsored by Badger Meter, referenced in the article, “Water Utilities Change AMR/AMI Systems More Frequently than Previously Thought” showed water utilities change their smart meter reading systems at an average age of 8.2 years. This 8.2-year average is far more frequent than the commonly referred to 20-year life expectancy for the meters themselves. John Fillinger, Badger Meter’s director of utility marketing states, “The study findings highlight the factors water utilities should consider and why it is important to plan for the true expected life of a new meter reading system.”  This is common industry knowledge as the frequent need to upgrade the AMI meters was also addressed in your former RFQ 16215.

As I previously testified in February 2020, I want to remind the commission that the current FCC approved safety standards are being challenged by lawsuits* and the potential non-compliance issues. Additionally, by the former RFQs own admission, should the possibility of reallocated FCC licensed frequencies go into effect, the entire AMI would be rendered inoperable. The current meter system does not pose such a catastrophic risk to the utility company or to the customer. It is extremely bizarre that with the current challenges of maintaining the existing infrastructure, you are willing to compound those challenges with in an inferior, risker product and spent approximately $100 million to do so. Furthermore, since WSSC operates as an enterprise fund, more rate increases will be imposed on customers to pay for something that we keep telling you we don’t want.

WSSC is innovative. You are leaders in the water utility industry -- out of state water utilities come here to learn from your expertise -- yet this insistence on following the herd and gambling close to $100 million on the problematic infrastructure of smart meters is frankly, dumbfounding.

There are alternatives available to accomplish the same goals without the health, cost and privacy risks. You already have technology for early leak detection that works effectively and is safe. Acoustic fiber optic (AFO) monitors PCCP 24/7 and warns of imminent pipe failures; Sahara, another acoustic based system, identifies real time leaks and pin points their locations. Continue being the visionary leaders that you already are. Perhaps consider downscaling the AFO or engineering a creative combination of fiber-acoustic robotics to install at the premises instead of smart meters.

Overall, AMI is a financially unsound investment. I oppose the implementation of AMI or any exorbitantly priced metering system that transmits radiofrequency microwave radiation.

I have presented no matter of mere 'concern' or any other non-substantive matter, but solely matters of substance, of fact and law.

 

 - A Montgomery County Resident