ADMINISTRATIVE LAW JUDGE’S RULING SEEKING CLARIFICATION
This Administrative Law Judge’s Ruling (Ruling) seeks clarification from Pacific Gas and Electric Company (PG&E), San Diego Gas & Electric Company (SDG&E), Southern California Edison Company (SCE) and Southern California Gas Company (SoCalGas) (collectively, the investor-owned utilities or IOUs) concerning the frequency and duration of radio frequency (RF) emissions from wireless smart meters.1 This clarification shall be filed by November 1, 2011.
On September 14, 2011, I held a combined workshop to consider alternatives for customers who wish to opt-out of a wireless smart meter. Representatives from the IOUs and the smart meter manufacturers2 were present to discuss the technological feasibility and costs of the various alternatives. During the workshop, there were various comments concerning the frequency and duration of the transmissions from the wireless smart meters. According to some parties, the wireless smart meters transmit data in short bursts throughout the day, with each burst lasting a few milliseconds. These parties state that, on average, the cumulative amount of time for the transmission would be 45 seconds a day. Other parties, however, state that while the transmission burst may only last a millisecond, the frequency of the transmission occurs so often that the transmission should be considered constant.
I want to make sure I fully understand this issue. Consequently, I am asking the IOUs to provide further clarification concerning the frequency and duration of the transmissions from the wireless meters and the associated RF emissions. PG&E, SDG&E, SCE and SoCalGas shall, therefore, respond to the following questions:
1. What is an average duration (in seconds) that a residential smart meter transmits in a 24 hour period?
a. How is this average computed or measured?
2. How many times in total (average and maximum) is a smart meter scheduled to transmit during a 24-hour period?
a. How many of those times (average and maximum) are to transmit electric usage information?
b. How many of those times (average and maximum) are for other purposes? What are those other purposes?
Please specify number of times (average and maximum) by type/category of transmission.
3. Under what scenarios does a meter transmit outside of the daily schedule, i.e., unscheduled transmission such as on-demand read, tamper/theft alert, last gasp, firmware
4. Typically, how much of the communication between the customer’s meter and the utility is unscheduled vs. scheduled?
5. Are there any other factors that go into determining duration and/or frequency of meter transmissions (e.g., if a meter can’t access the network when it’s trying to send data, type of a meter etc.)? If yes, please identify these factors.
6. What is the amount of RF emission at the source when a meter is transmitting data (instantaneous maximum peak level, averaged over 30 minutes)?
7. Does the amount of RF emission vary depending on duration of transmission/volume of data being sent? For example, are RF emissions higher when there is a larger volume of data to be transmitted?
8. Are there any other factors that impact the amount of RF emissions? If so, please identify the factor(s) and its impact on RF emissions.
9. Is there RF emission when the meter is not transmitting? If yes, what is the amount of RF emission?
10. Is there a difference in the amount of RF emissions for a wireless smart meter with the radio off and a smart meter with the radio out? If yes, what is that difference and how is it calculated?
11. Is there a difference in the amount of RF emissions for a wireless smart meter with the radio off and an analog meter? If yes, what is that difference and how is it calculated?
As part of their responses to the questions above, the IOUs shall identify
the individual who prepared the response to each question. The IOUs shall file
their responses to the questions listed above by November 1, 2011.
IT IS RULED that by November 1, 2011, Pacific Gas and Electric
Company, San Diego Gas & Electric Company, Southern California Edison
Company, and Southern California Gas Company shall file a response to the
questions concerning radio frequency emissions listed in this Ruling.
Dated October 18, 2011, at San Francisco, California.
/s/ AMY C. YIP-KIKUGAWA
Amy C. Yip-Kikugawa
Administrative Law Judge
As used in this Ruling, a wireless smart meter is a digital electric or gas meter that transmits customer usage data through radio transmission.
The smart meter manufacturer representatives were from ITRON, Silver Spring Networks, and Aclara.
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