WSSC Violates Their Mission

Dear WSSC Commissioners and AMI Project Team     

I am a Montgomery County resident. I attest and affirm under the pains and penalties of perjury that the following statements are true and accurate and within my personal knowledge.

Thank you for giving me the opportunity to comment on WSSC’s plans to provide wireless smart meters for all of its 475,000 customer accounts in Montgomery and Prince George's Counties.  

I admire WSSC’s mission 
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;

• to continuously enhance and protect natural resources and the environment for the health of future generations;
• to achieve the highest level of quality, safety, productivity, and cost-effectiveness;
• to be a good citizen within our communities and plan proactively with community stakeholders;
• and to acquire the best people, retain top performers, and develop and grow talent.

A WSSC plan that would eliminate meter reading jobs and in their place install devices that pose threats to the public and have questionable reliability, runs counter to your mission.

The cost of converting to wireless smart meters is immense, estimated at $102.5 million by WSSC. In today’s uncertain economic times, recovering these costs will likely result in rate increases as WSSC attempts to maintain technically complex wireless smart meters that will likely have shorter lifetimes than current metering technology. These rate increases will be an increased burden for families that are already struggling to pay their utilities with job and income loss due to COVID-19.

The immense cost of converting to AMI smart meters will also likely result in the laying off of nearly all WSSC staff who read meters. At this time our country and Montgomery and Prince Georges Counties are experiencing extreme rates of unemployment. According to the latest numbers available from the Maryland Department of Labor, unemployment rates as of June 2020 in Montgomery County were 8.1 percent, and in Prince Georges County were 9.9 percent (up from 2.9 and 3.6, respectively, in February 2020). (Retrieved 8/19/20 from https://www.dllr.state.md.us/lmi/laus)

Unions that represent meter readers in other jurisdictions that have adopted AMI smart meters have long asserted that AMI kills meter readers’ jobs. For example, the International Brotherhood of Electrical Workers Local 1837 in Maine reported in 2008 that the switch to various forms of automated meter reading threatened the jobs of approximately 100 revenue data readers. According to IBEW member Bill Dunn, the loss of meter readers is a loss of workers who play a critical role as “birddogs” during storms and other outages. And, according to the IBEW, the loss of meter reader jobs results in the loss of an opportunity for a good entry-level position that has historically been a stepping stone to linework. In the COVID-19 era it is noteworthy that a loss of meter reading jobs is also a loss of jobs that are done outdoors, making them safer than other employment options these workers could search for. (Retrieved 8/19/20 from https://www.ibew1837.org/content/automated-meter-reading-has-big-impact-workers-cmp-asks-puc-rate-increase-implement-system ).

The mandated installation of wireless smart meters, as currently contemplated by WSSC, would ignore the rights of property owners to control which equipment is installed on their property, especially in the absence of an unpaid opt-out option. A paid opt-out option, though better than no option, would unfairly radiate customers who can’t afford the added fee. And neither an unpaid, nor a paid, opt-out option would protect the public from the radiation from their neighbors' wireless smart meters.

Scientific evidence of harm from radiofrequency radiation has been growing for decades and has become overwhelming. Thousands of scientific studies have documented clear evidence of harm to human health from this radiation including neurologic effects such as sleep impairments, learning and memory problems, dementia and tinnitus; cardiac and blood pressure effects; endocrine and immune effects; genotoxicity; cancer; and more. Such adverse outcomes and others are established in the scientific literature of nearly 25,00 studies. No mere matters of “concern”, these rather constitute facts of lack of safety and environmental health science.

For example, in 2018 the NIH National Toxicology Program found "clear evidence" that radiofrequency radiation causes cancer, which I do not consider to be a “minimal” impact. National Institute of Environmental Health Sciences National Toxicology Program. (2018, March).  “National Toxicology Program Peer Review of the Draft NTP Technical Reports on Cell Phone Radiofrequency Radiation”. Retrieved from https://ntp.niehs.nih.gov/whatwestudy/topics/cellphones/index.html.

Furthermore, the World Health Organization classifies radiofrequency radiation as a Group 2B human carcinogen. Additionally, 253 of the world's leading EMF scientists appealed to the UN and the WHO to protect the public from harm from radiofrequency radiation, including the radiation from smart meters.

The health consultant WSSC is relying on, Dr. Leeka Kheifet, is not only paid by wireless companies to testify in their defense, but has also been a longtime consultant for Electric Power Research Institute (EPRI). This is a violation of your mission to be ethical and transparent.

Please uphold your mission of providing safe and reliable water, honoring and valuing your employees, protecting the health of future generations, and being a good citizen within our communities. Please do not implement wireless AMI smart meters on our homes.

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

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