Delegate Al Carr Testimony to WSSC "Carefully Evaluate" the $100M AMI SmartMeter Project

 

September 3, 2020

Washington Suburban Sanitary Commission Budget Division
14501 Sweitzer Lane
Laurel, MD 20707

via email to budgetgroup@wsscwater.comRe: CIP Testimony

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

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

3. 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

Maryland’s 18th Legislative District