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In support of S.8765 which seeks to establish consumer protection and utility meter choice

Presenters:

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Les Jamieson

Member of New Yorkers 4 Wired Tech

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William Bathgate

BBEC, EMRS, IEEE RFSO

Vice President of the Residential Consumer Group

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Odette Wilkens

Attorney, founder of NY Wired Broadband

February 7, 2023

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As it is, S.8765 provides benefits to utility customers with residential accounts by offering them the ability to retain use of their analog meter without fees being imposed. The following provisions would provide additional consumer protections to a broader scope of state residents:

There are many thousands of NY residents who own multi-family homes. In the interest of their rights as property owners, it is important that they be able to have analog meter choice for their entire property, not just the unit they live in. They need to be able to opt out for their rental units, and for accounts covering common areas within the building, such as hallways. Currently, hallways are designated by the utilities as being commercial. There is no opt out choice for any accounts designated as commercial

Owners of small businesses with accounts designated as commercial need to have analog meter choice. These include restaurants, and all manner of neighborhood shops. Owners and their staff spend substantial time in close proximity to utility meters.

Residents and pedestrians near buildings with digital meters installed on their exterior need protection from exposure to their RF emissions which are pulsed frequencies. This can be done with meter covers made up of a protective shielding material. Ideally, there should also be shielding behind the meter panel as well.

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Large residential buildings have large panels with utility meters. These panels with digital meters also need to have meter covers made of protective shielding material. If the location of the digital meters is adjacent to living space, there needs to be shielding behind the digital meters as well.

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Note: The current electronic meters as deployed today are in violation of Equipment Authorization of the FCC, which requires a minimum physical separation of 20 cm (7.8 Inches) from the surface of the meter in all directions to prevent hazardous human exposure.

Proposed additions to S.8765 or possibly a companion bill

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The Effect of the Appeals Court Ruling on Digital Meters

Policy makers working to serve the interests of their communities and the general public would benefit from the information to follow.

But first, policy makers need to be aware that the utilities claims of compliance with FCC guidelines refer to the Telecommunications Act of 1996 are unfounded due to the United States Court of Appeals for the District of Columbia Circuit decision on Aug. 13, 2019 establishing that the FCC’s refusal to update their guidelines was “arbitrary and capricious”. This decision was upheld on Aug. 20^th, 2021 when the court stated:

…the agency demonstrated “a complete failure to respond to comments concerning environmental harm caused by RF radiation.” The court found the FCC ignored numerous organizations, scientists  and medical doctors who called on them to update limits and the court found the FCC failed to address these issues:

• impacts of long term wireless exposure
• impacts to children, 
• the testimony of people injured by wireless radiation, 
• impacts to wildlife and the environment 
• impacts to the developing brain and reproduction.

See https://ehtrust.org/in-historic-decision-federal-court-finds-fcc-failed-to-explain-why-it-ignored-scientific-evidence-showing-harm-from-wireless-radiation/

AMI Meters add to CO²/Climate Change and Higher Bills

By William Bathgate, BBEC, EMRS, IEEE RFSO

Vice President of the

Residential Consumer Group

January 25, 2023

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Note: This report has been written in terms that a common person with limited knowledge of electricity and engineering can understand.

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William practices as a professional in electrical engineering and mechanical engineering disciplines. He was recently employed at Fiat Chrysler Automotive on electronics systems for such things as radio communication for electric and autonomous vehicles etc. William was previously employed through late 2015 for 8 years at the Emerson Electric Company. While at Emerson Electric he was the Senior Program Manager for Power Distribution Systems and in charge of RF and IP based digitally controlled high power AC power switching system product lines in use in over 100 countries. He was also directly responsible for product certifications such as UL (USA), CE (EU), PSE (Japan) and many other countries electrical certification bodies. He is very familiar with the electrical and electronic design of the AMI meters in use because he was responsible for very similar products with over 1 Million units installed across the world. William also has over 20 years work experience with IBM and Hewlett Packard in computer systems design and manufacturing.

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He holds a DOD Top Secret Clearance, serving in Cyber Security with the US Missile Defense Agency, NASA and Homeland Security. He is a Certified Building Biologists and a Certified Electro Magnetic Radiation Specialist by the Building Biology Institute https://buildingbiologyinstitute.org/. He is an IEEE Certified Radio Frequency Safety Officer and conducts radio antenna surveys for assurance to the FCC specifications.

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He is Vice President of the Residential Consumer Group https://residentialcustomergroup.org/. This organization has legal representation in all Public Utility Rate Cases submitted in Michigan. To date the group has caused the cancellation of numerous rate increases in excess of over 1 Billion in increased utility costs to Michigan Residents.

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He has done this analysis due to his own curiosity without conflict of interest of this new technology. He has 40 Years work experience in design and deployment of:

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High tech power management systems, UPS and power distribution

Switched Mode Power Supplies

Electrical and Electronic hardware engineering

Computer systems engineering

Radio Systems design and testing

High Current and High Voltage switches

Internet communications using both wired and wireless technologies

UL, CE (Europe), Africa, Japan, Australia and China product safety certifications

Cyber encryption (DOD Level) and protection of Radio Communications using digital signals

RFI/EMI mitigation

 BACKGROUND: William S. Bathgate

�Agenda – What you need to know�

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• The assertion that the RF from an AMI meter is less than a cellphone is simply proven as untrue.
• The AMI meters are increasing CO² causing climate change, not preventing it.
• Billing and KWh/Carbon Footprint calculation issues you were not told of.
• The infrastructure of AMI networks are not 100% secure and private. Analog meters are.
• The suggestion that consumers can use AMI meter information to reduce their energy use is a fabrication because the consumer data is not real time. The one Day old data is useless.
• The suggestion that AMI meters are more accurate is false. AMI and analog meters both have to meet the ANSI C12 specifications on accuracy.
• The Meter RF signal can travel 1,400 – 1,500 feet, right through a brick wall, making an opt out program useless in an apartment complex scenario. This is from the one of the meter manufacturers itself.

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It is not less than a cell phone call �The Truth on RF Smart Meter Emissions

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µW/CM²

Note: 1µW/CM²

= 10,000 µW/M²

The Smart meter is 400,000 µW/M² peak @ 10 ft it is 100,000 µW/M² peak

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Smart Phone is

0.25 µW/CM² = 2,500 µW/M² peak

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Source – Dr. Daniel Hirsch on the CCST Report – is all in µW/CM²

CCST = California Council on Science and Technology

Note – Initial ERPI report but corrected for whole body exposure vs at the ear for a cell phone. The original report from CCST measured at less than 3 RF wave lengths from the source i.e. cell phone right at the ear lobe. When conducting RF measurements you must consider the recommended distance between the RF source and the instrument antenna. Typical rule is 3.

The common assertion that the Smart Meter emits less RF than a cell phone is untrue.

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Examples of Digital Meter Installations in Apartment Buildings

Note this is exceeding the FCC equipment Grant

separation distance of 20 cm

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Examples of Digital Meter Installations in Apartment Buildings

From the FCC Equipment Grant (ITRON Meter Example)

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Examples of Digital Meter Installations on Exterior Walls

Albemarle St. and Nostrand Ave. in Brooklyn

51^st Street between 4^th and 5^th Avenue in Brooklyn

Building Biology International Safety Standards for RF for Human Exposure

As anyone who walks within 3 Meters of these meters their exposure is considered an Extreme Concern @ 14,245 µW/M²

How far can the AMI meter transmit?

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• Between 1,400 ft and 2,300 ft. An AMI can also transmit thru a brick wall, wood, drywall etc.

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How far can the AMI meter transmit?

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• At 1,400 ft and 2,300 ft. RF would impact a consumer especially in an apartment or condo complex. If just one consumer request an opt out meter, that consumer would be impacted by anyone within 1,400 feet that has an AMI meter. The same is true in single family home residences or neighborhood.

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• The utility consistently states the RF emissions of the meters meet FCC requirements, this is a misleading statement. FCC requirements are for the effects of enough non-ionizing power to cause the brain to  heat up 1° C. This is a deception because there are effects of non-ionizing radiation. There have been over 800 peer reviewed independent studies not funded by the industry that have linked this type of low level non-ionizing RF radiation to a group of diseases including brain cancer, Parkinson's, Alzheimer's, high blood pressure, tinnitus, skin rashes and open sores as an example. Industry funded studies always fail to point our that 32% of their  funded studies show an effect on health from non-ionizing radiation. The industry NEVER mentions these studies. This adds to confusion on the health effects attributed to the meters. I have personally met many of the affected consumers and this is no joke or set of psychological conditions. 
• https://magdahavas.com/wp-content/uploads/2020/04/Havas-5G-health-humans-and-biota-April-15-2020.pdf

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�AMI – “AMI - Smart Meters” use power from the Grid to operate – This adds to Climate Change�

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• Consider that the AMI meter is actually a powerful computer, not a just a meter. In fact, the federal government classifies the AMI as a computer, not a meter.
• The AMI meters require power from the grid to run the computer inside the meter.
• There is a Two Way radio in each AMI meter
• There are special circuits that convert the AC power to DC to power the electronics of the circuit boards, CPU’s, memory switching power supplies, LCD’s, a solenoid and many others functions, etc. Those all consume power.
• The analog meter consumes no power to operate. It has no electronics inside.

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�How much power does the AMI meter consume?�

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• I did a field test of the meter on my own home. I was in a unique position of not living in the home at the time and there were no lights or appliances operating.
• I turned all the breakers off in power panel, so there was nothing “On”.
• The result was the AMI meter consumes ~2.7 KWh ’s per day on average. Multiply that times the number of meters. It’s a big number. It did not “Save” any power.

My Smart Meter Test Setup

• Subsequently I built a special test set up so I can repeat the same test at any time. I can plug in any AMI meter in and see how much power the meter consumes all by itself. I get the same ~2.7 KWh ’s/day regardless of meter brand. Analog meters consume no power.

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Proof - My Field Test - My Energy Insight Readings – Michigan example �Average Daily AMI kWh Use 2.37 kWh @ 0.13 per kWh = $0.31/day (865 kWh/Yr.)�

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Note – No breakers were on and the time and reading of the meter is not a simple “Text” message these are clearly two way communication activity and the power to run the meter itself. It is not the same as a simple cell phone call.

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This data was from Detroit Edison, as the reported power consumption on the home, with all the power off!

Impact to the Environment – Detroit Example

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Conclusion: There is absolutely NO evidence the AMI Meter program saves CO², energy in kWh or money, in fact it only drains the bank accounts of the impoverished consumer, pads utility revenue and adds to Global Climate Change.

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The only way the AMI program will save kWh’s is to use it to ration power to consumers via Demand Response/Time of Use rate structures at 5-10 X normal rates where the elderly, disabled and young families with a parent and small children at home can least afford it or do without power during the Demand Response/Time of Use period. Under this scenario the AMI program is the largest fleecing of the consumer to ever exist and a deception to our citizens regarding saving power, reducing costs, reducing CO² and protecting our environment. We would be better off taking the money to be invested in AMI meters and plant trees.

Note: Solar is 2.2 Lbs. total Embedded CO²/kWh including Mining, transport, maintenance, etc.

AMI is not Secure – It has a Physical Back Door

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There is a special tool that is used to program the meter. A malicious actor can easily obtain one of these tools.

A physical connection to the meter directly by-passes encryption, allowing privacy to be violated and hacking risk; insertion of code, altering the network traffic and injecting malicious code. They can even shut down the power. The default passwords are published in the meter documentation.

Network Weak Link

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A malicious actor can send a strong RF broadband signal (multiple frequencies all at once) pointed at this network point, blocking transmission and no readings can be sent to the utility. The AMI meters have tamper protection in them and when they do not get an acknowledgment back from the utility over a certain period of time they begin to shut down. You do not need to know the encryption key, just block the transmission to the network access point with an overwhelming RF signal

Back Door to the Data, Zigbee Net

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Once access via the gateway is enabled there is no firewall to block data access, so personal email, video downloads data, etc. can be accessed by utilities and hostile actors. If you can get on the ZIGBEE network you can observe all this type of data. I can easily hack my neighbors ZIGBEE 2.45 GHz network and see all his information Realtime.

Smart Meter - Day Old Data - will never let a consumer help prevent a “Brown Out” �

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Note – These are the readings of my electric use coming from DTE. This data is a day old. It is impossible to adjust my usage today based on usage from yesterday. Yesterday is gone and nothing can be done about it. Unless the meter information is “Continuously Real Time” there is no purpose in building out this capability. The utility costs to provide day old data is pointless. It is cute to see this information but the consumer cannot change behavior to effect a result to something that has already occurred.

�AMI versus Analog Meter Accuracy�

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Key Differences

• Analog Meter
• The Analog meter has a direct one-for-one relationship between the current consumed in kWh’s  and the wheels turning the dials. There is no influencing factor or software that can alter this relationship. Also, since this is a current measuring device with no electronics, it is not readily affected by extremes in temperatures and humidity or short circuits. 

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• The analog meter has a means to direct excessive power surges to the house ground rod per UL 1449 specs. The life span of the analog meter is typically 30-50 years and is UL Listed (which means it is stamped with the UL logo). It has the same ANSI C12 specs for accuracy as the AMI meter. Categorizations that the AMI meter is more accurate is not true, since they both must meet the same ANSI C12 specs.

AMI versus Analog Meter Accuracy�

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Key Differences

• AMI Meter
• The AMI measured current does not have a one-for-one relationship between current consumed and indicated reading. This must be measured via an electronic sensor, converted to a digital signal and then a computer calculation averages all of the sensor input and posts the data in computer memory and the reading  on the LCD display. There is a manipulation of the indicated reading  that can be affected by many factors.

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• All electronics components are rated between 1% to 20% accuracy. Most of the components on the AMI meters are 5% rated, with the current transformers rated at 1% accuracy within the permitted range of temperatures. I will point out that this 1% is only related to temperature, not the measured load characteristic. This is important because testing at the University of Twente in 2016  showed very high smart meter inaccuracies of 582% (https://www.utwente.nl/en/news/2017/3/313543/electronic-energy-meters-false-readings-almost-six-times-higher-than-actual-energy-consumption) with current transformers, such as in the all AMI meters, are generally accurate to within ±10%. That is a 20% range. So claims by utilities that the AMI is more accurate is highly suspect. This is only true in a very tightly controlled setting such as ten 100 watt incandescent bulbs, not with electronic appliances, motors, CFL’s, LED’s etc.  (Note - a 100 watt light bulb can vary 5%)

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AMI versus Analog Meter Accuracy

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Key Differences

• The ANSI C12 Standard – “Gold Standard" Missing
• The standard that all meters must meet is ANSI C12. It sounds impressive, however, there are two extremely important characteristics that this standard leaves out – a Gold Standard for reference and a real time clock to calculate kWh hrs.

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• I found it amazing to discover ANSI C12 does not present a “Gold Standard” reference for all meters to be compared to. For example your average meat market has a weight scale which is calibrated to a known standard such as weights in standard calibrated sizes for pounds and ounces. There is a seal affixed to that scale to assure the consumer they are not getting cheated. This characteristic does not exist in the ANSI C12 Standard.

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AMI versus Analog Meter Accuracy�

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Key Differences

• The ANSI C12 Standard - Real Time Clock

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• There is no time standard reference in the ANSI C12 specification. In other words no “real time clock”.  The analog meter did not need a clock; the gears in the meters did the calibrated settings to indicate kWh’s. This is extremely important because without a universal time standard, the AMI computer circuitry has no standard means to measure current consumption over a known reliable time period.  So, how it calculates kWh measurements requires a very reliable and uniform time standard. In computer circuitry, a time synch process in the “stack” of processes is the least serviced characteristic leaving other more important computational process to have a higher priority.  You may have had a home computer, which was not connected to the Internet where the indicated clock reading is off occasionally, with the time reading tending to drift a bit. The RF Emitting AMI meters have a means to keep the clock synced via the mesh network or cellular network.  However, the Opt-Out AMI meter has no network connection so its clock will drift over time, which will affect the calculation of kWh’s. So, a consumer may not get the actual reading of the power they consumed. The Analog meter uses the gears to indicate the reading and does not drift, and therefore maintain accuracy.  
• If you have an AMI opt out program, you must use an analog meter to be accurate to the ANSI C12 standard.

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AMI versus Analog Meter�

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Key Differences

• The ANSI C12 Standard - Real Time Clock

• This is important to recognize because many utilities offer a Non – Communicating AMI meter. This has no real time clock reference. It will give erroneous readings as I have experienced.

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• Here is a photo of my meter installation. Note my calibrated analog meter is in series with my electronic AMI opt out meter. I read both meters every month at the same time and day of the month and compare them. I typically find the Electronic AMI is a higher reading than the Analog meter. I send these findings to the utility and they adjust my bill down to a matching reading. The utility now has given up any added charges of $10.00/month to my bill for manually reading my AMI meter.

Meter accuracy and your bill

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• As professed by Landis+Gyr, their AMI meter is “accurate” based on the Navigant Consulting Report in 2010 and referenced their web site. However, within this report the extremely high rate of billing complaints after the installation of the new meters is evident and explanations were difficult to verify as to their cause.  The number of complaints was dramatic. This baseline of complaints was done in Texas with real temperature ranges from ~30 to ~88 degrees. 

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• Control testing conditions were not well explained in this report such as ambient temperatures ranges, and in particular the type of load the meter accuracy was compared to.

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• Resistive loads such as light bulbs with standard incandescent bulbs (linear loads), versus CFL’s, Halogen, Switched mode AC/DC power supplies i.e. Home phone chargers, TV and appliance controls, LED’s and overhead florescent light with electronic ballasts (non Linear loads).   
• Inductive loads such as electric motors in refrigerators, washing machines air conditioners etc.
• No discussion on how the AMI meters did the kWh calculation, since it is really not a meter, but is a computer, with peak samples not averaged over a fixed period of time? Whatever your peak use is in a 15 minute window is what you get charged for the full 15 minute window.

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• What is very different in the AMI meter is the algorithm used to calculate the readings from the sensor into the indicated display. The analog meter is a type of “totalizing” meter just like a gas pump. The AMI meter is very different, typically using peak use as a basis for calculations over a fixed window of time. ( any peak in 15 minutes is used for billing the entire 15 minute window)
• The AMI meter uses sensor data, which has to be averaged by a mathematical calculation, then registered into memory and on the LCD display.
• The gas pump has a weights and measures standards sticker to assure the consumer they are getting what they paid for, there is no such concept on an AMI meter.  ANSI standards are laboratory measurements under tightly controlled conditions and are inadequate for accounting for in the field variances for temperature and humidity.

Meter accuracy and your bill

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• The Navigant Report tried to explain the billing inaccuracies in Texas using complex mathematic explanations and reference to “degree” days, but the degree variance was typically within 10% year over year, yet this did not explain power bills increasing as much as 25%-40% higher year over year.
• Their test lab control setups were done at room temperature as shown in pictures in the report. 
• There was no field test at various temperatures for accuracy, nor was there a test using electric motors, they only lab tested with incandescent light bulbs, two completely different load variables.

Electric Motor Current Draws are different than a light bulb

• There is a short .5 to .6 sec burst of current needed to start an electric motor, so a 5 amp rated motor may need 8-9 amps to get rotating up to rated speed.
• If the utility is measuring peak current and averaging this over a window of time you can skew the average when you combine the two types of loads.
• Only the utility knows the math in the software.
• If you have an “Energy Star” refrigerator/freezer, it starts and stops frequently, and so the skew of the average is worse, imagine the impact on the average reading after 3-5 motors start and stop in the sample window.

�Conducted Emissions “on the wire” �

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• US FCC Title 47 Part 15.109 and International Standard CIPSR 32 Conducted Emissions (EMC and EMI/RFI)

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• The AMI meter, Opt-Out Meter (no RF) and various versions of the Electronic meters all currently exhibit spiked high frequency voltage transients and magnetic common mode currents backwards onto the home wiring system creating a huge antenna amplifying these transients and magnetic currents. 
• There is no way to “fix” the current design without a direct connection to an Earth Ground source and a circuit redesign.
• An external fix at your service panel costs anywhere from $2,000 to $7,000 for UL approved filters. 
• Customer appliances are breaking down, especially any appliance with an electric motor or critical electronics including pace makers, CPAP machines and other life sustaining medical equipment .
• People are getting sick from the both RF generating and the Opt-Out meters as the result of conducted emissions and common mode currents.

SMPS with Common Mode Filter – Principles You Need to Understand

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The Standard Single Phase 60 Cycle/Second Waveform with EMI/RFI introduced by the SMPS

This waveform displayed is the same as an oscilloscope trace would look like, you cannot see this on a common voltmeter.  Now we have introduced the effects of EMI/RFI via the SMPS to the same wire carrying the house current. This effect can be less depending on the environment, especially  how good the house earth ground is magnetically coupling the house voltage currents Especially if they are using the water pipe as a ground reference which makes it worse. There are many variables that affect this waveform. The image in red should never be there, I have found this pattern consistent with every AMI meter, including the AMI meter with the radios off and the various digital meter alternatives. It is typically not compliant to FCC rules over all required frequencies for “conducted” Emissions Class A or Class B.

The claim the meter meets FCC specs, maybe not true

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Here is an example:

This the section of a report on a Sensus brand meter that is non compliant at 300 KHz note they are over spec for both FCC QP and AV Class B specs

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I have the full reports of each example I present here. These are the parameters for “Conducted Emissions” not the RF 900 MHz transmissions

How does the utility get a non- compliant meter accepted as compliant?

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Here is an second example:

The previous section of a report on the same Sensus brand meter that is non compliant at 300 KHz where they are over spec for both FCC QP and AV Class B spec. They then submitted a second report to the Iowa Commission for the same meter a report that obviously “Cherry Picks” the data points avoiding the 300-320 KHz frequency range to make it appear to be compliant. They avoided the graph shown in the previous chart. I find this be a common ploy in submission for approvals to state commissions. Since the meter companies pay the certification service they can be easily influenced to create a report favorable to outcome the meter company desires.

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AMI meter without Common Mode Filter – Principles You Need to Understand

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The Standard Single Phase 60 Cycle/Second Waveform with EMI/RFI introduced by the SMPS

The image in red is for both AMI meters (with the radios on or off) and the various forms of “Electronic Meters." They are not compliant to FCC rules for “conducted” Emissions Class A or Class B. Shown here are the limits for CONDUCTED emissions not Radio Emissions, which is a different specification, which are being fed back into the home wiring at the load panel. This is placing stress on all electronics and electric motors in the home, causing early appliance motor failures, appliance electronic control failures and radio interference, in addition to health effects such as insomnia, tinnitus, headaches, high blood sugar levels  and nervous disorders such as neuropathy and heart arrhythmia. In order to become compliant the meter manufactures would have to scrap the current SMPS design, and include one that connects to an earth ground path to sink the oscillations to the home ground rod.  

Class A

limits

What can be done to remove conducted emissions within the meter?

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• A complete redesign of the SMPS board to include UL and FCC specifications for "conducted" emissions of EMC/EMI/RFI and stray common mode magnetic currents.
• Inclusion of common mode filter components.
• Inclusion of a direct connection to an Earth Ground to “Sink” the Conducted Emissions directly to ground.

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Summary

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