IN THE MATTER OF POTOMAC ELECTRIC POWER COMPANY AND DELMARVA POWER AND LIGHT COMPANY REQUEST FOR THE

DEPLOYMENT OF ADVANCED METER INFRASTRUCTURE IN THE MATTER OF BALTIMORE GAS AND ELECTRIC COMPANY FOR AUTHORIZATION TO DEPLOY A SMART GRID INITIATIVE AND TO ESTABLISH A SURCHARGE MECHANISM FOR THE RECOVERY OF COST

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Case No. 9207

Case No. 9208

Smart Meter Opt-Out Comments Public Service Commission Staff April 6, 2012

Table of Contents
Executive Summary ...................................................................................................................... 1 Background ................................................................................................................................... 3 Maryland Smart Grid Activity ................................................................................................ 3 Opt-Out Activities in Other States .......................................................................................... 3 Opt-Out Provision Effect on AMI Benefits and Costs .............................................................. 5 Lower Benefits ........................................................................................................................... 5 Higher Costs............................................................................................................................... 7 Lower Cost-Effectiveness ......................................................................................................... 7 Opt-Out Provision Effect on Meter Configuration.................................................................... 7 Opt-Out Provision Effect upon the Utilities Energy Programs .............................................. 9 Structure, Integration, and Cost of an Opt-Out Program ........................................................ 9 Conclusion ................................................................................................................................... 12

ExecutiveSummary
On February 29, 2012, the Maryland Public Service Commission (Commission) issued a Notice of Hearing and Opportunity to Comment on an Opt-Out Option for Smart Meters. The purpose of the hearing is for the Commission to consider issues relevant to or associated with providing customers with an opt-out option as well as the appropriate structure for any such opt-out requirement should the Commission determine the option to be in the public interest. The issues include, but are not limited to: a. The effect such an option on the overall smart meter projects costs and benefits, including the effects on energy savings, outage detection, and management and incremental costs; b. How such an option might affect the current schedule for installing the smart meters; c. Whether such an option will affect the types, components and/or configuration of the meters available to customers who choose to opt out of a smart meter; for example, whether an opt-out option would be limited to not enabling some or all of the communications capability of a smart meter; d. The effect such an option might have upon future meter reading; e. The effect such an option might have upon the communication of data between the utility and customers; f. The effect such an option might have upon the utilitys future billing practices; g. The effect such an option might have upon the utilitys electric tariff rate structures as will an any energy programs; and h. The structure of any opt-out program, including the effect on customer education, the means by which a customer might opt out, the means by which customers might re-enroll, how such an option would be administered to new customers within the utilitys service area, and any charges that should be imposed on customers who choose to opt out. Staff does not support an Opt-out option for Baltimore Gas and Electric Companys (BGE) or Potomac Electric Companys (PEPCO) Advanced Metering Infrastructure (AMI) deployment projects for the following reasons: The Commission decision to approve the deployment of AMI did not assume in the review of the cost-effectiveness of the plans that customers could opt out of the deployment.

An Opt-out provision would reduce the Operational savings because Operational and Management (O&M) services that were to be eliminated because of AMI would be needed to provide services for the opt-out customers. For example, meter readers would be needed to record the electricity usage of the opt-out customers, which would require truck rolls, maintenance of meter reading equipment, maintenance of vehicles and fuel costs. An Opt-out provision could reduce the Supply side savings due to less participation in the Peak Time Rebate Dynamic Pricing construct, leading to less energy and demand savings, which leads to lower capacity and price mitigation benefit. An Opt-out provision would lead to higher project costs. For example, new educational materials would need to be developed and approved, new metrics would need to developed and approved, and higher costs for potentially having to remove already installed smart meters and the potential for several visits to a specific address for installation of the smart meter if a new customer moves into a house without a smart meter, wants to have the smart meter installed. An Opt-out provision will produce a lower quality service for opt-out customers and perhaps for customers who do not opt out as well. For example, opt-out customers will not have the benefit of improved, outage management and power quality monitoring that is made possible by advanced meters. Because communications with BGE and PEPCO meters depends on a mesh configuration (a particular meter will often communicate with the backbone network through another meter rather than communicating directly with a network receiver), customers who opt out create holes in that mesh. This means that neighbors of an opt-out customer may also have a lower quality service than they otherwise would have or the cost of extra receivers must be incurred to compensate for these holes in the smart grid. An Opt-out provision makes it impossible for the utilities to achieve such benefits as theft of service detection and a full understanding of grid usage (for example voltage levels at the premise and distribution transformer loading) for those customers who opt out.

Staff notes that the Commission established a Regulatory Asset for the costs of deploying the AMI system and the cost recovery was contingent on both Companies demonstrating that they delivered a cost-effective system. The Commission noted that a large portion of the projected benefits of the deployments was from supply side benefits; capacity revenue, capacity 2

mitigation, etc., and that there was an element of uncertainty in the projection of these supply side benefits. An Opt-out provision would only serve to increase these uncertainties in expected benefits and changes the foundation of the business cases the Commission reviewed in the acceptance of BGEs and PEPCOs AMI proposals.

Background
MarylandSmartGridActivity
In 2010, the Commission approved the AMI proposal for BGE, granted conditional approval for PEPCOs AMI proposal, and deferred the approval of Delmarva Power and Light Companys (DPL) AMI proposal until DPL can demonstrate the cost effectiveness of a revised business case for its AMI proposal. In 2011, the Commission authorized PEPCO to deploy its AMI project and held additional evidentiary hearings on DPLs revised business case. In Order Nos. 83531 and 83571 in Cases Nos. 9208 and 9207, respectively, the Commission directed BGE and PEPCO to develop a comprehensive set of installation, performance, benefits and budgetary metrics that will allow the Commission to assess the progress and performance of the Initiative. Additionally, the Commission directed BGE and PEPCO to develop comprehensive customer education plans for Commission approval. Following the Commissions direction that workgroups be established to bring stakeholders together with the utilities for the development of metrics, educational programs, and security standards, a number of initiatives were undertaken in 2010 and 2011. In a letter order dated February 18, 2011, PEPCO received approval from the Commission to implement its Proposed Phase I customer education plan. In a letter order dated July 18, 2011, BGE received approval from the Commission to implement its Smart Grid Customer Education and Communication Plan. In a letter order dated August 18, 2011, the Commission granted approval for the Phase I Metrics for both BGE and PEPCO. The workgroup continues to develop plans for cyber security, Phase II metrics, and Phase II customer education and communication. It is expected that consensus filings and specific plans will be filed for approval on each of these issues in 2012.

OptOutActivitiesinOtherStates
As with many new technologies, the advent of the Smart Grid has brought skeptics to the forefront. States across the U.S. are now dealing with complaints from utility customers who

claim that smart meters have proven to be unreliable in tallying energy usage and even unsafe. Utility commissions from two states, Maine and California, have approved opt-out provisions for the utilities they regulate.12 Both states will permit a utility to charge opt-out customers for an initial fee and a recurring monthly charge. Utilities in other states are following suit. Nevada Energy must file its cost estimates of opt-out provisions with the Nevada Public Utilities Commission in late April;3 two Vermont utilities have filed to commence their opt out monthly charges in 2013;4 and Detroit Edison in Michigan has preemptively created its own opt-out plan for customers ahead of any efforts the Michigan Public Service Commission may take.5 In Georgia, the state senate approved a bill mandating opt-outs for customers of Georgia Power, although the legislative session has now ended without further action on this bill.6 Table-1 Customer Charges by Opt-Out Option in California7 Analog Meter Initial Fee Monthly Charge Exit Fee $270 $16 $130 Radio-Out $270 $15 $130 Wired Meter $470 $41 $130 Radio-Off $270 $14 $130

The impetus for establishing opt-out provisions stems in part from utility customers around the U.S. worried about the health effects associated with the transmission of radio waves from smart meters. While any new technology is likely to engender concerns about its safety,
1 2

State of Maine Public Utilities Commission, Docket No. 2010-345, Order (Part 1). California Public Utilities Commission, Proceeding A. 11-03-014, Application of Pacific Gas and Electric

Company for Approval of Modifications to its SmartMeter Program and Increased Revenue Requirements to Recover the Costs of the Modifications, Decision Modifying Pacific Gas and Electric Companys Smart Meter Program to Include an Opt-Out Option.
3 4 5 6

http://www.lasvegassun.com/news/2012/feb/29/regulators-allow-nv-energy-customers-opt-out-smart/ http://vtdigger.org/2012/03/21/psb-no-smart-meter-opt-out-fees-for-cvps-gmp-customers-until-at-least-april-2013/ http://www.sourcenewspapers.com/articles/2012/03/30/news/doc4f75b0b877124539369824.txt http://www.legis.ga.gov/legislation/en-US/Display/20112012/SB/459 California Public Utilities Commission, Proceeding A. 11-03-014, Application of Pacific Gas and Electric

Company for Approval of Modifications to its SmartMeter Program and Increased Revenue Requirements to Recover the Costs of the Modifications, Decision Modifying Pacific Gas and Electric Companys Smart Meter Program to Include an Opt-Out Option p. 27.

concerns regarding the safety of smart meters are very likely unfounded. The Federal Communications Commission mandates that all smart meter devices must meet radio frequency exposure limits it has established.89 While smart meters do emit a radio frequency, its potential effects are exaggerated by opponents of the technology. The following is a chart of the power density of radio frequency for various, commonly used devices: Table-2 Power Density in Microwatts per square centimeter (W/cm2) Adjacent to a gas SmartMeter (1 foot) Adjacent to an electric SmartMeter (10 feet) Adjacent to an electric SmartMeter (1 foot) Microwave oven nearby (1 meter) Wi-Fi wireless routers, laptop computers, cyber cafes, etc., maximum (~1 meter for laptops, 2 - 5 meters for access points) Cell phones (at head) Walkie-Talkies (at head) Source: Richard Tell Associates, Inc. (2008)10 While smart meters do indeed emit a radio frequency, its intensity is less than a microwave, laptop, or a cell phonedevices that are much more common in use. In addition, most meters are positioned so that residents are more than 10 feet from the meter at most times, further lessening their effects, and generally are operating only for a few minutes during a 24 hour period. 0.00166 0.1 8.8 10 10 - 20

30 - 10,000 500 - 42,000

OptOutProvisionEffectonAMIBenefitsandCosts
LowerBenefits
In both Companies business cases, benefits related to AMI were divided into two categories, Operational or O&M savings and Supply side savings, attributable to reductions in peak demand and energy use due to participation in the Peak-Time Rebate Dynamic Pricing
8 9

47 C.F.R. 1.1307(b), 47 C.F.R. 1.1310, 47 C.F.R. 2.1091, 47 C.F.R. 2.1093. http://www.aeic.org/meter_service/smartmetersandrf031511.pdf, p11-12. http://www.pge.com/myhome/edusafety/systemworks/rf/

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construct. An Opt-out provision would reduce the Operational savings because O&M services that were to be eliminated because of AMI would be needed on a continuing basis to provide services for the opt out customers.11 Smart meters will eliminate the need for meter readers (without any employee layoffs) and will diminish the number of trucks needed to cover a service territory when reading analog meters. Not only would labor costs associated with meters increase, the costs associated with truck rolls would return, including maintenance costs and gasoline costs. While some trucks may be eliminated depending on the scope of opt-outs, several will be still be required even if the number of opt-outs is small or moderate, largely because opt-outs may occur in any part of the service territory. The task will not be as simple as one employee and one truck completing the route of analog meter reading. Because of these needed resources, opt-out provisions will likely roll back the financial benefits resulting from O&M savings more than any other category. Other areas of O&M savings that would be affected by an Opt-out provision include outage detection and restoration, remote connection and disconnection not related to failure to pay, and meter tampering and theft of energy. Under Phase II of the AMI rollout, the Utilities will undertake dynamic pricing efforts, savings that were within the original contemplation of the original orders approving AMI in 2010. While opt-out customers themselves would not wholly eliminate these estimated benefits, allowing an Opt-out would trim the amount of estimated savings associated with dynamic pricing. Opt-out provisions would affect 24 different metrics under Phase II (currently under discussion) related to dynamic pricing and energy saving benefits. Virtually all of the savings associated with these programs rely upon smart meters to accomplish the task. Monetary and energy savings from dynamic pricing events and other measures will not just be affected in the BGE and PEPCO service territories. Opt-out provisions will affect the energy prices in other Maryland service territories, which would otherwise be lower in the aggregate due to the lower price of the energy in BGE and PEPCO territories stemming from dynamic pricing events, use of energy management tools, and conservation voltage reduction. Opt-out provisions would also affect savings from capacity price mitigation as well. Smart meters are expected to reduce the RPM demand curve to BGE, PEPCO, and all other Maryland customers stemming from the use of energy management tools and conservation voltage reduction. Opt-out provisions would even affect the benefit of avoided transmission infrastructure resulting from reduced peak load. While the number of opt-out customers may only amount to a fraction of the service territory, even a small amount of them will affect several anticipated energy and monetary benefits stemming

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Operational savings covered approximately 80 percent of the total AMI project cost for both BGE and PEPCO.

from dynamic pricing programs, and these effects will have cascading effects throughout BGEs and PEPCOs respective business plans.

HigherCosts
An Opt-out provision would lead to higher project costs. For example, new educational materials would need to be developed and approved, new metrics would need to developed and approved, and higher costs for potentially having to remove already installed smart meters and the potential for several visits to a specific address for installation of the smart meter if a new customer moves into a house without a smart meter, and wants to have the smart meter installed.

LowerCostEffectiveness
The end result of lowering project benefits and increasing project cost is to lower the cost-effectiveness of the AMI project for both BGE and PEPCO. The magnitude of the change is highly dependent on the number of customers who decide to opt out of receiving a smart meter. The Commission has directed that the Companies can seek recovery of project costs after proving the delivery of a cost-effective system, based on the business cases that did not contemplate an Opt-out provision. Therefore, if the Companies are directed to provide an Optout provision to their customers, the cost-effectiveness of the overall project will need to be reevaluated to account for this change in program design.

OptOutProvisionEffectonMeterConfiguration
While the Utilities may comment on the communications capabilities of their respective smart meters, Staff is unaware of an alternate communications capability on the meter, such as an analog function with the transmission mode shut off. Maine and California came to different conclusions regarding meter capabilities for opt-out customers. Maine will offer two options regarding meter choicean electro-mechanical meter ($40 initially and $12 monthly fee) or a standard smart meter with network interface card (NIC) operating in receive-only mode ($20 initially and $10.50 monthly fee).12 California, however, has adopted the analog meter opt-out option only.13 For anyone requesting an opt-out, the customer will not have the option to obtain

12 13

State of Maine Public Utilities Commission, Docket No. 2010-345, Order (Part 1), p. 2-3. California Public Utilities Commission, Proceeding A. 11-03-014, Application of Pacific Gas and Electric

Company for Approval of Modifications to its SmartMeter Program and Increased Revenue Requirements to Recover the Costs of the Modifications, Decision Modifying Pacific Gas and Electric Companys Smart Meter Program to Include an Opt-Out Option, p. 20.

a smart meter but will be required to retain their analog meters. Ultimately, no group of states thus far has set a precedent of how opt-out customers will be treated. Each state is likely to handle this issue according to its best interests, and Maryland should examine this issue from a perspective of determining what is least burdensome upon the AMI rollout. Staff is unaware of whether or not PEPCOs and BGEs advanced meters are capable of functioning while shutting off their radio transmitter. However, provided that BGEs and PEPCOs meters do possess this function, Staff recommends that the least burdensome approach would be to proceed with the installation of AMI meters, and customers who desire to opt out be allowed to have their radio transmitters shut off. This would permit the Utilities to still deliver AMI meters as originally planned without an unwanted radio frequency on the part of the customer, and it allows them the opportunity to switch the meter back to full functionality in the event the customer changes his or her mind or that a new customer replaces the one opting out at that particular property. Table-3 Estimated Costs for Opt-Out Options in California14 Analog Meter Initial Costs Meter Initial Costs Labor Monthly Charges Other Costs Network Capital Costs IT Costs Call Center Operations Expenses Other Costs $36,385,335 $2,317,621 $3,007,620 $15,371,390 $57,081,966 $36,385,335 $2,317,621 $3,007,620 $15,371,390 $57,081,966 $411 $36,385,335 $25,983,287 $3,007,620 $45,308,990 $115,766,712 $613 $36,385,335 $2,317,621 $3,007,620 $15,371,390 $57,081,966 $402 $51.24 $128 $10.69 Radio-Out $29.28 $128 $10.69 Wired Meter $355.50 $128* $10.42 Radio-Off N/A $128 $10.69

Revenue per Opt-Out Customer** $416

NOTES: * Excludes additional $150.00 for wiring charge. ** Assumes 145,800 Opt-Out Customers

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Id. at p. 26.

OptOutProvisionEffectupontheUtilitiesEnergyPrograms
As discussed earlier in the Benefits section of this report, the Utilities will undertake dynamic pricing efforts, generating savings that were within the original contemplation of the original orders approving AMI in 2010. While opt-out customers themselves would not wholly eliminate these estimated benefits, their effect would trim the amount of estimated savings associated with dynamic pricing. There are two other programs, energy management tools and conservation voltage reduction, that could be affected by an Opt-out provision. The Smart Grid Work Group is developing metrics to measure the costs and benefits of energy management tools and conservation voltage reduction. Similar to dynamic pricing, the metrics will measure such benefits as demand and energy savings, capacity and energy revenues, and capacity and energy price mitigation. Additionally, the demand and energy savings will be reported in the quarterly and Semi-Annual EmPOWER Maryland reports and will be counted towards achieving the 2015 EmPOWER Maryland peak demand and energy usage reduction goals. Staff notes that although the Smart Meters have the ability to record usage on more frequent basis and to communicate that information directly back to the utility, this project can be classified as a normal operation for the utility companies, similar to upgrading distribution substation equipment or maintenance activities such as tree trimming. A customer cannot opt out of receiving distribution substation maintenance, tree trimming, or pole replacement projects, therefore, customers should not be permitted to opt out of receiving a new smart meter, which for all intents and purposes is recording the customers electricity usage for billing purposes. The Commission also requires that all residential customers pay a surcharge for BGEs and PEPCOs direct load control programs, even though not all residential customers are eligible to participate, because they do not have central air conditioning or a heat pump. The reason all residential customers pay the surcharge for these programs is because all residential customers benefit from these programs in the form of lower capacity and energy prices through capacity and price mitigation. These benefits will also flow through to all customers through the Peak Time Rebate pricing program, which is only able to be active because of the smart meter.

Structure,Integration,andCostofanOptOutProgram
If the Commission directed BGE and PEPCO to implement an Opt-out provision in their respective AMI projects, there would be several tasks to undertake prior to implementation. One of the first tasks that would need to be undertaken would be a revision to the customer education

plans, which were approved for PEPCO on February 18, 2011,15 and for BGE on July 18, 2011.16 The Utilities would have to reprint certain materials to account for new information related to opt-outs and how digital and analog meters will now be handled. Further, the Utilities would be required to create an entire new set of communications materials as well as a supplemental communications plan to inform their customers about the opt-out and the procedures involved for doing so. A supplemental plan would also require a strategy to circumvent the spread of information in the original communications plans now running counter to opt-outs. The total effort involved would add significant costs to the Utilities communications budgets, which had originally contemplated having already spent a large portion of their respective funds to date. An effective structure for an opt-out program would be to stay ahead of AMI rollout where possible. While PEPCO is well underway with its rollout, BGE has just recently started its AMI rollout. If an opt-out strategy is approved in Maryland, such a strategy may need to be implemented expediently so that most customers can opt out of AMI meters before they are installed in their communities. This strategy could save labor involved in reinstalling analog meters where AMI implementation has already taken place. However, even if the Commission were quick to approve an opt-out program, the Utilities would still have to reinstall analog meters in service territory already served by AMI. The provision of adequate notice would allow an opt-out program to be completed in an orderly way. In Maine customers have 30 days in which to enroll in an opt-out program before smart meters are installed in their area, after which, a customer may still enroll for a $25 surcharge (Central Maine Power may waive the surcharge if it determines there is a sufficient reason for the customers failure to notify CMP within the 30day period).17 Notice would play a large role in allowing customers to opt out of the AMI rollout. A protocol regarding the way in which Maine will operate would most effectively reach customers prior to rollout. Notice could come in the form of a mail insert within a bill, a stand-alone letter from the Utility, and/or information posted on the Utilitys website. The most imperative issue is for the Utility to determine when the 30-day notice would commence, during which the customer must respond. For customers whose neighborhood has not undergone AMI implementation, the
15

Case No. 9207, In the Matter of Potomac Electric Power Company and Delmarva Power and Light Company

Request for the Deployment of Advanced Meter Infrastructure, Letter authorizing Pepco to implement the Proposed Phase I Plan, p. 1.
16

Case No. 9208, In the Matter of the Application of Baltimore Gas and Electric Company for Authorization to

Deploy a Smart Grid Initiative and to Establish a Surcharge for the Recovery of Cost, Letters to Party(ies) noting the approval Baltimore Gas and Electric Company Customer Education and Communication Plan, p. 1.
17

State of Maine Public Utilities Commission, Docket No. 2010-345, Order (Part 1), p. 3.

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Utilities could ensure that this 30-day notice period would end prior to the scheduled installation date for that area. This process would mitigate the number of field visits made to a particular area when the Utilities undertake AMI installation there. Reenrollment by customers would not likely require a notice period, merely obtaining easily accessible information regarding how to re-enroll within the AMI program. Such information could be placed upon utility websites and would likely require employees be trained to handle such matters, in particular customer service representatives at call centers. Customers new to a utilitys service area would likely require a 30-day notice period, potentially beginning the day remote connection is restored to the property. Upon calling a customer service representative to establish service at a residence, the Utility would have the customer as a captive audience and be able to inform the customer of the right to opt out of the AMI meter program. These examples show that the means by which to inform customers of their right to opt out would not be unreasonably burdensome so long as customers are given adequate notice, and there may be other effective means customers, both current and future, to opt out of the AMI program. Similar to the structure of other states, an opt-out program would likely include both initial and monthly charges to customers exercising the option. With the Commission and the two Utilities having undergone a detailed and thorough effort to ensure that an AMI rollout would be cost effective, and with several million federal dollars at stake, the Commission must allow some means by which utilities could cover the expenses associated with opt-out provisions.18 Because these provisions were not in the contemplation of the original AMI implementation plan, the Commission must allow a system of charging to account for the difference between what would have been an otherwise cost effective plan and what opt-out provisions will cost the utilities. Charges imposed upon customers choosing to opt out should account for all of the costs and unrealized benefits of AMI as a result of creating an opt-out option. The Utilities should perform an analysis to determine an estimate for how many customers they would anticipate will opt out from AMI meters in their service territories. All costs and unrealized benefits should be divided out among the estimated number of participants to create an average cost per customer opt-out. This user-fee means by which to charge a customer opting out would ensure that the Utilities will closely maintain the cost effectiveness of their plans in the face of a major change in their respective rollouts.

18

Both BGE and PEPCO have received Federal grants for the implementation of their AMI programs. Even if the

Commission is otherwise inclined to permit an Opt-out for the programs, it should make certain that the Federal funding will not be unduly affected by such a change.

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Conclusion
While Staff understands the concerns of citizens regarding smart meters and the new technology they bring, it emphasizes that the technology also creates opportunities yielding monetary and energy savings whose efficiencies ultimately reach back to the customer. Staff does not support an Opt-out option for BGE or PEPCO AMI deployment projects for the following reasons: The Commission decision to approve the deployment of AMI did not assume in the review of the cost-effectiveness of the plans that customers could opt out of the deployment. An Opt-out provision would reduce the Operational savings because Operational and Management services that were to be eliminated because of AMI would be needed to provide services for opt-out customers. An Opt-out provision could reduce the Supply side savings due to less participation in the Peak Time Rebate Dynamic Pricing construct, leading to less energy and demand savings, which leads to lower capacity and price mitigation benefit. An Opt-out provision would lead to higher project costs. An Opt-out provision will produce a lower quality service for opt-out customers and perhaps for customers who do not opt out as well. An Opt-out provision makes it impossible for the utilities to achieve such benefits as theft of service detection and a full understanding of grid usage (for example voltage levels at the premise and distribution transformer loading) for those customers who opt out.

If the Commission requires Opt-out provisions, Staff recommends that the Commission: Maintain the cost-effectiveness of the business plan in Case No. 9207; Maintain the cost-effectiveness of the business plan in Case No. 9208; Order BGE and PEPCO to create estimates of the number of customers in their respective territories who are likely to opt out; Order BGE and PEPCO to estimate how much the aggregated customers would diminish the expected savings of the AMI rollout; Order BGE and PEPCO to divide the expected costs of opt-out provisions including any additional costs that will be required to provide to make certain that customers who do not opt out will have the quality of service anticipated with no

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Opt-out provision among the expected number of customers opting out to create an average cost; and Apply the average cost as an initial and monthly charge to be paid by any customer choosing to opt out of smart meters.

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