TABLE OF CONTENTS

Health and Safety Issues Cost Savings and Energy Conservation Claims Privacy Issues Do the Benefits Outweigh the Risks and the Practical Aspects of an Opt Out Program

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Health and Safety Issues

BGE admits on page 5 of its April 6, 2012 comments that there have been no safety studies conducted on smart meters. This is the crux of the problem, and BGE admits to it. Dr. David O. Carpenter, Director of the Institute for Health and the Environment at the University of Albany, State University of New York, as well as Dr. Karl Maret, physician, bioengineer and smart meter authority, and a large body of scientific and medical authorities are all in concurrence on the point that quite simply, there are no studies on the health effects of smart meters, particularly once the home area mesh network and routers are fully functional. In view of this, it is clear that as far as public health and safety are concerned, the precautionary principle must prevail. The burden of proof is on the utilities to prove to the public, through independent, long-term studies that the smart grid is safe for humans and the environment. In the words of Cindy Sage, internationally renowned environmental consultant: No positive assertion of safety can be made by the parties involved in this issue without better, independent information. Currently the data made available by the utilities that are installing smart meters is non-existent, piecemeal and without sufficient basis to verify. BGE cites on Page 5 of its comments the report of the California Council on Science and Technology in claiming that when properly installed and maintained, wireless smart meters result in less RF exposure than cell phones. Dr. Daniel Hirsch, Radiation Scientist and Nuclear Policy Expert at the University of California, Santa Cruz, did an extensive critique of this report. He stated: The draft report by the California Council on Science and Technology (CCST) does not appear to answer the questions asked of it by the requesting elected officials. Furthermore, rather than being an independent, science-based study, the CCST largely cuts and pastes estimates from a brochure by the Electric Power Research Institute, an industry group, issued some weeks earlier. The EPRI estimates appear incorrect in a number of regards. When two of the most central errors are corrected the failure to take into account duty cycles of cell phones and microwave ovens and the failure to utilize the same units (they should compare everything in terms of average whole body exposure) the cumulative whole body exposure from a Smart Meter at 3 feet appears to be approximately two orders of magnitude higher than that of a cell phone, rather than two orders of magnitude lower. Following are two charts that compare microwave radiation from smart meters to cell phones, microwaves and other devices. The first is from the CCST report- the second is from Dr. Hirschs study corrected for whole body, cumulative exposure.

The CCST report mixed units and published this highly misleading chart. When the chart is properly corrected, one sees that the smart meter exposure far exceeds that of cell phone exposure.

Chart produced by Daniel Hirsch, corrected to represent cumulative, whole body exposure. This chart is corrected to reflect the same units of measurement thereby showing that smart meters are at least 100 times more powerful than cell phones.

Dr. Olle Johansson, Associate Professor, The Experimental Dermatology Unit, Department of Neuroscience, Karolinska Institute commented on this same CCST Report: Many smart meters are close to beds, kitchens, playrooms, and similar locations. These wireless systems are never off, and the exposure is not voluntary. The smart meters are

being forced on citizens everywhere. Based on this, the inauguration of smart meters with grudging and involuntary exposure of millions to billions of human beings to pulsed microwave radiation should immediately be prohibited until the red flag can be hauled down once and for all. Dr. Magda Havas, expert on RF exposure, was presumably invited to contribute to the CCST Report. Clearly they decided to discard her recommendations. Nonetheless, her position can be seen in the following comment: We have evidence that pulsed microwave frequencies ...are more harmful than continuous wave and yet this is not considered in the FCC guidelines (Reno 1975). With more frequencies being used, with the levels of radiation increasing, and with so little research on the long-term, low-level effects of this technology we are creating a potential time bomb. If smart meters are placed on every home, they will contribute significantly to our exposure and this is both unwise and unsafe. (Havas Report on Smart Meters for CCST, Oct. 2010) http://www.magdahavas.com/wordpress/wpcontent/uploads/2011/01/Havas-Report-CCST-Smart-Meters.pdf Dr. David O. Carpenter, mentioned above, also raised serious objections to the CCST Report: This document is not an accurate description of the state of the science on the issue of radiofrequency fields. My specific concerns are as follows: 1. The benefit of the smart meters is entirely to the utilities, and is economic in nature 2. When a smart meter is installed residents have no choice in the matter nor ability to avoid exposure... 3. The statement The potential for behavioral disruption from increased body tissue temperatures is the only biological health impact that has been consistently demonstrated and scientifically proven to result from absorbing RF within the band of the electromagnetic spectrum that smart meters use is totally wrong 4. The statement The scientific consensus is that body temperatures must increase at least 1 degree Centigrade to lead to potential biological impacts from the heat is totally wrong, and makes it obvious that no persons with medical or biological expertise participated in this report 5. The statement While concerns of brain cancer associated with mobile phone usage persist, there is currently no definitive evidence linking cell phone usage with increased incidence of cancer is incorrect 6. The statement There currently is no conclusive scientific evidence pointing to a non-thermal cause-and-effect between human exposure to RF emissions and negative health impacts is inaccurate, and depends totally on what one defines as conclusive...

7. The evidence for adverse effects of radiofrequency radiation is currently strong and grows stronger with each new study (To see comments in their entirety, go to http://www.schoolmoldhelp.org/content/view/2145/65/) BGE cites on page 6 of its comments the Utilities Telecom Council (UTC) 2010 Article that concluded smart utility devices pose no health threat. But what is the UTC? A quick check at its website yields the following information: The Utilities Telecom Council (UTC) is a global trade association dedicated to creating a favorable business, regulatory, and technological environment for companies that own, manage, or provide critical telecommunications systems in support of their core business. Founded in 1948 to advocate for the allocation of additional radio spectrum for power utilities, UTC has evolved into a dynamic organization that represents electric, gas, and water utilities; natural gas pipelines; critical infrastructure companies; and other industry stakeholders. The UTC can be counted on to promote the industry rather than to provide reliable, independent assessment of health problems associated with the industrys products." (Sage Associates). This is a wolf in wolfs clothing, and any scientific work in this area must be taken with a grain of salt. On page 5 of the comments BGE states the Electric Power Research Institute (EPRI) found that the RF field levels from smart meters are below the exposure limits of the FCC. Following, Cindy Sage of Sage Associates responds to the EPRI Report: "EPRI (The Electric Power Research Institute) conducts research on issues of interest to the electric power industry, and is largely funded by electric utilities in the United States EPRI did not present calculations using the FCC OET Bulletin 65 equations that are fundamental to predicting RF levels. Thus, no apples-to-apples comparison can be made from their selective presentation of examples of RF levels. EPRI gave none of the basic information needed to check their figures. They provided no comprehensive assessment using the same FCC OET 65 equations, nor the range of possible duty cycles or reflection factors, nor specifying what power output, gain, effective radiated power (ERP) or other critical factors were used in their selected examples But, policy makers must not just look after the interests of industry, but take good public health planning principles into account. When there is reasonable evidence for risks from new technologies, it is not in the public interest, nor the economic interests of the State to wait endlessly for all parties to agree there is causal evidence or proof position in order to take reasonable actions to protect public health. This is particularly true when considering the wisdom of widespread, involuntary public exposures to new technologies for which there is substantial 6

evidence (but not yet proof) of possible health harm to millions of people. It could cost billions to fix in later years, result in economic harm to the State and its residents, and cause even deeper dissatisfaction with the States regulatory agency performance." To see her comments in their entirety, go to: http://sagereports.com/smart-meterrf/?page_id=460 BGE states on page 7 of its comments that the World Health Organizations (WHO) Category 2B is one of the lowest levels on the International Agency for Research on Cancer (IARC). According to Dr. Annie Sasco, MD, MPH, MS. Dr. PH, Harvard Doctorate and ex-head of the International Agency for Research on Cancer (IARC) says that there was enough evidence that the WHO classification of RF electromagnetic radiation could easily have been classified as a "2A" probable carcinogen--not just possible. http://www.youtube.com/watch?v=2JyAlO_UdSk But regardless of which cancer category WHO or IARC puts RF radiation into, it is irresponsible for an industry to impose on millions of people a technology suspected of causing cancer without any testing whatsoever. BGE seriously understates the amount of radiation emitted from its smart meters on page 5 of its comments. BGE claims that these meters only transmit at most 1% of the time. But according to Dr. David O. Carpenter, "It is true that smart meters transmit information for only a very small period of time. But the problem is that they generate RF constantly, so when they transmit is irrelevant." Utilities claim that the pulsed signals from data transmission only add up to about 45-62 seconds per day. But this is deceptive. A smart meter transmits nanosecond pulses from a few times a second to once every 6-8 seconds. So people are being bombarded with radiation pulses constantly even if the cumulative time of the actual nanosecond pulses adds up to only 45-62 seconds per day. Pacific Gas & Electric recently admitted that the average number of RF pulses for their electric meters would be about 14,000 per meter, per day, with a maximum number of over 190,000. This is very different from their initial assertions which ranged anywhere from once every hour to once every 4 to 6 hours. According to tests recently performed by Pepcos own technicians in the home of attorney Chris Turner, who lives in PEPCO's service area, his meter, like those of PG&E, was sending out thousands of pulses per day. Pepco defended its position saying that since the meter is only talking to PEPCO six times a day, and the other transmissions were the meter talking to the mesh network, their statement was somehow true.
Regardless of the purpose of the RF emissions, the meters generate pulsed, microwave radiation 24/7.

BGE claims on page 5 of its comments that the health, safety and reliability of our system are extremely important to BGE. It is difficult to take this statement seriously in light of the pleas of thousands of doctors across the world for action to protect children from this form of radiation. The International Commission for Electromagnetic Safety, The European Environment Agency and the European Parliament, consider the current guidelines to be obsolete and that lower values are needed to protect the public. The Irish Doctors' Environmental Association (IDEA) Position Paper on ElectroMagnetic Radiation states, There is now a large body of evidence that clearly shows that this is not appropriate, as many of the effects of this type of radiation are not related to these thermal effects. In the Freiburger Appeal 3000 doctors have urged for world leaders to protect children from the harmful effects for EMR listing concerns such as difficulty with learning and concentration, extreme fluctuations in blood pressure, heart rhythm disorders, heart attacks and stroke in younger populations, brain generative diseases, cancer, leukemia, brain tumors, headaches, migraines and chronic exhaustion. Doctors from Italy, USA, Sweden, Austria, Germany, Jerusalem, Israel, Poland, and Sweden have synergized their knowledge and come together to sign the Catania Resolution to voice their concerns in order to protect children and adults from EMR. The Helsinki Appeal, and doctors from 13 countries have signed the Benevento Resolution to protect children from electromagnetic radiation. Status Report on Investigations of Potential Human Health Effects Associated with Power Frequency Electric and Magnetic Fields (EMF) prepared for the Maryland Public Service Commission in October of 2006 by Sandra S. Patty, Transmission Program Manager of Power Plant Research Program, and Doreen Hill, Ph. D. of Hill Consulting This study prepared for the Maryland Public Service Commission, looks at the association of EMF near Maryland power lines with elevated numbers of childhood leukemia. While this study did not involve RF radiation directly, it does demonstrate that EMF can be quite harmful and it may suggest we should give pause before immersing ourselves and our children into a deluge of EMF/ RF technology. Additionally, if safety is important to BGE, it seems to have ignored the voluminous numbers of studies and research articles on EMF/EMRs (samples and links listed below). What studies have the utilities done that contradict the overwhelming body of evidence cited below? Links to compendia of research articles on the health effects of exposure to radio frequencies BioInitiative Report The International Commission for Electromagnetic Safety International EMF Alliance EMF Safety Network (Global EMF Websites) Microwave News 8

EMF Facts Consultancy Electromagnetic Health.org Dr. Magda Havas, PhD. EM Radiation Research Trust EMF Radiation News The EMR (Electromagnetic Radiation) Network EMR Policy Institute Environmental Options EMF Network Environmental Health Trust Citizens for Safe Technology Center for Safer Wireless The Swedish Association for the ElectroSensitive Powerwatch EM Watch ElectroSensitivity UK ElectroSensitivity.Org The Candian Initiative to Stop Wireless, Electric and Electromagnetic Pollution EMR Australia Burgerwelle Mast-Victims.org Chronic Exposure.org

Following is a List of Government Agencies and Reports from University and Non-Profit Collaborative Research Groups on the Health Effects of Human Exposure to Radio Frequencies:
1. American Academy of Environmental Medicine; Electromagnetic and Radiofrequency Fields Effect on Human Health. In the last five years with the advent of wireless devices, there has been a massive increase in radiofrequency (RF) exposure from wireless devices as well as reports of hypersensitivity and diseases related to electromagnetic field and RF exposure. Multiple studies correlate RF exposure with diseases such as cancer, neurological disease, reproductive disorders, immune dysfunction, and electromagnetic hypersensitivity. 2. Parliamentary Assembly of the Council of Europe Committee Resolution 1815, Adopted in plenary session, Strasbourg, May 27, 2011, The Council of Europe, representing 47 member countries, adopted a resolution recommending sweeping changes to the way cell phones are used, how they are marketed, and how safe exposure limits are determined. 3. European Parliament Voting 522 to 16, the European Parliament passed a landmark resolution on September 4, 2008 recommending tighter safety standards for cell phone and cordless telephone use. Noting the already lowered exposure limits of some European countries the EU Parliament is now calling on the EU Council to amend the Recommendation 1999/519/EC still further for all equipment producing emissions in the 0.1 MHz to 300 GHz frequency range. This would include cell phones as well as other wireless devices.

Wireless technologies that rely on microwave radiation to send emails and voice communication are thousands of times stronger than levels reported to cause some health impacts." 4. The BioInitiative Report Fourteen scientists and researchers from around the world reviewed over 2,000 studies on EMFs. They found a link between EMFs, cancer and other health problems. The 200 page report concludes that the existing standards for public safety are inadequate to protect public health. 5. Canadian Human Rights Commission In Medical Perspective on Environmental Sensitivities,by Margaret E. Sears, M..Eng. Ph.D, the author states, "Given the seriousness of the adverse effects and the availability of alternative technologies, a precautionary approach is warranted." 6. The French Agency for Environmental and Occupational Health and Safety has recommended reducing peoples exposure to electromagnetic emissions...because questions remain about possible health effects. 7. The State of California, Santa Cruz County Board of Health calls for more government vigilance towards involuntary RF public exposure. Additional links to studies on the health effects of human exposure to radio frequencies can be found at: http://www.bioinitiative.org/freeaccess/ http://www.justproveit.net/studies http://www.createhealthyhomes.com/cellphone_risks.php BGE claims in Exhibit 1 of their comments through the testimony of Dr. Peter Valberg that smart meters are safe. With all due respect to Dr. Valberg, MSMA would like to remind the commissioners that he is a physicist, not a person with any training in medicine. Moreover, it is common knowledge that he has been a spokesperson for the utility industry for most of his professional career. Contrasted to what Dr. Valberg has to say, there is a substantial body of scientific literature from unbiased sources that are sounding the alarm on RF radiation. We ask the Commissioners to please take note of the fact that the totality of BGEs "proof of safety" comes from: 1. The CCST study, rebutted by numerous experts, as shown earlier in this document. 2. The EPRI, which is largely utility funded. 3. The Utilities Telecom Council, which as noted earlier , exists to "promote the industry rather than to provide reliable, independent assessment of health problems associated with the industrys products." (Sage Associates) 4. The comments of Dr. Peter Valberg, a spokesperson for the utilities almost his entire professional career.

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Contrast this with the statements of numerous mainstream, key organizations whose very missions are public-health related, and with the statements of scientists and doctors who have no vested interest in this issue, and yet are sounding the alarm on smart meters. Organizations such as the Karolinska Institute, one of Europe's leading medical universities that appoints the laureates for the Nobel Prize in Medicine and one of the top medical research institutions in the world, and the American Academy of Environmental Medicine, are among a growing list of organizations, with no agendas other than public health and welfare. Yet they are all issuing warnings on the dangers of smart meters: (Links below) http://www.scribd.com/doc/48148346/Karolinska-Institute-Press-Release http://ppjg.me/tag/american-academy-of-environmental-science/ http://www.smartmeterdangers.org/index.php/position-statements/192-santacruz-healthdept-sm-report-position In the second part of Exhibit 2, in its comments, BGE claims that smart meters are safe citing the Work of Klaus Bender of the Utilities Telecom Council;
Please refer to our comments earlier on lack of objectivity of the UTC.

We invite the Commissioners also to read this rebuttal to Klaus Bender: http://eon3emfblog.net/wp-content/uploads/2010/11/Rebuttal-to-Klaus-Bender.pdf including the studies listed at the end, under the heading Required Reading for Mr. Bender. Possible safety impact of broadband over power lines In the last few days it has been brought to the attention of MSMA that a major component of the smart grid may be something called Broadband over Power Lines, (BPL) that transmit energy usage and other data over power lines. According to emerging research, this produces a hum that causes debilitating health effects on a small percentage of the population. MSMA would like transparency from the utilities as to whether or not Marylands smart grid is in fact using Amperions patented signal structure, BPL. Due to the fact that an opt-out will not remediate the problem of the RF radiation emissions from the wireless mesh network and access towers, nor will it address the possible problems with BPL, MSMA is calling for a moratorium on the smart grid in Maryland until these problems are resolved through independent study of the current literature and further research.

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Cost Savings and Energy Conservation Claims

BGEs claims that smart meters will conserve energy and save the ratepayers money are unsupported by actual experience. BGE claims on page 15 of its comments dated April 6, 2012, that ratepayers who opt out will be at an economic disadvantage: From a customer perspective, the most significant impact would be the lost opportunity to earn energy savings discounts or rebates. Customers without a smart meter could not participate in SER and have the opportunity to earn peak time rebates. Also, these customers would not have the benefit of interval usage data, high bill alerts and running bill totals that will be available through the new customer web portal functionality that is expected to help customers conserve energy and save on their bill. Henry David Dieners comments of April 3, 2012 (mail log #138168) explain that the normal ratepayer will more likely be stuck with higher energy bills, not lower ones. Pacific Gas & Electric commissioned a study by Freeman Sullivan & Company of its smart meter program to determine if there were any significant energy savings. That study, mentioned in Mr. Dieners comments, 2010 Energy Conservation Evaluation of Pacific Gas & Electric Companys Energy Alerts and Customer Web Presentment Programs (April 29, 2011) concluded that there were no savings. The studys recommendation section on page 28 of that report contains a disturbing observation: In any case, it seems unlikely that CWP [Customer Web Presentment] alone has a large impact on residential usage. Future evaluations should focus on whether there are ways to drive more customers to CWP and whether there are different CWP offerings that actually lead to significant usage reduction. Recommendations for Energy Alerts are similar to those for CWP. Currently, few customers have signed up for Energy Alerts of those marketed to. There is no evidence of any conservation among those customers who did sign up. BGEs claim that customers who opt out will somehow be missing lots of savings is completely unfounded. What we see in the above study is that the extravagantly expensive smart meter effort was launched with little thought given as to whether this system would ever have any practical benefit for the customers. Now that they are installed, the study is trying to find ways to make it work. We now have a solution in search of a problem. This rush to judgment characterizes the entire AMI program. Instead of carefully evaluating if smart meters make practical sense, determining whether the radiation they emit is dangerous, and making sure they do not invade our privacy, utilities like BGE and PHI are rushing to install them regardless of whether this makes sense. In addition, missing from this analysis is some recognition of the human costs that smart meter deployments will almost certainly generate. A certain percentage of the public that is sensitive to this form of radiation will be forced to leave their homes with all the resultant disruption and costs. While it is difficult to quantify, the human and out of pocket costs of only one case of cancer, those costs would cancel out a significant portion

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of the somewhat marginal savings we have seen. But what if the experts are correct in that smart meter radiation generates hundreds or even thousands of cases of cancer. Even if the victims had a difficult time proving their cases in court, the litigation costs for BGE and PHI would be spectacular, eliminating even the most optimistic predictions of energy and cost savings. If the victims successfully prove their cases, then both BGE and PHI would probably have to consider bankruptcy protection.

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Privacy Issues
BGEs privacy experts testimony actually supports MSMAs position on privacy BGE on April 19, 2012, submitted to the Public Service Commission of Maryland the testimony of Jules Polonetsky regarding the privacy issues presented by smart meters. (Mail Log No. 138591). While BGE undoubtedly submitted his testimony to support its position that the smart meter program did not present any significant privacy issues, the testimony only underscores our concerns. The first issue we have with Mr. Polonetskys testimony is the danger of sharing the data with third parties. On page seven he states: Unless the data collected is shared with third parties that are more than just utility service providers, the collection through smart meters of operational and analytical data does not pose significant privacy risks. BGE, in its testimony before the Maryland House Economic Matters Committee on March 15, 2012, admitted that it was going to ship all the smart data to a third party to make up the electricity bills. In addition, we have seen in other states (Ohio and Texas) where the utilities have furnished energy use information on individual rate payers to law enforcement authorities without search warrants. There is no reason to believe that cannot happen in Maryland. The second major issue is Mr. Polonetskys hope that somehow BGEs abiding by the Fair Information Practice Principles (FIPs) will protect the ratepayers from unwanted invasions of privacy. While we agree that these principles are widely accepted, one of these principles is enforcement and redress. There is none here. No Maryland state agency has been established to protect the ratepayers when their privacy is violated. The individual ratepayer will have to sue BGE to get redress, an unlikely event. What we have here is self-regulation. Unfortunately we have seen the disastrous consequences when companies are left to self-regulate. Here are just three painful examples: the banking scandals of the 1980s, the investment scandals that launched the recession we are in now, and Department of Interiors allowing oil drillers in the Gulf of Mexico to essentially self-regulate. BGE has stated to the PSC that its policy is not to share this data with third parties. But that is only a policy. The financial temptation to provide this data to marketers coupled with lack of any meaningful enforcement is a prescription for disaster. But even if BGE kept all the data in house, and there was adequate enforcement, this still does not address the issues of hackers gaining access to this data. Pacific Gas & Electric has already admitted that hackers have gained access to ratepayers meters, but it has refused to indicate how often this is happening. The federal National Institute of Standards and Technology (NIST) explained in its Guidelines for Smart Grid Cyber Security, Volume 2, Privacy and the Smart Grid (2010) 1 that consumer data moving through a smart grid becomes stored in many locations both within the grid and within the physical world. Because it is widely dispersed, it becomes more vulnerable to interception by unauthorized parties and to accidental breach. This movement of the data also increases the risk for it to be stolen by third parties while it is in transit, particularly

As summarized in the Congressional Research Service report, Smart Meter Data: Privacy and Cybersecurity (February 3, 2012) at page 7.

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when it travels over a wireless network or through communications components that may be incompatible with one another or possess inadequate security protections. Interestingly, page 9 of BGEs comments of April 6, 2012, contains encrypted information from a typical smart meter. While it looks at first glance to be unreadable, one of our members was quickly able to glean some significant information from the encrypted data such as when it was sent, how big the message was and which meter was involved. An experienced hacker would probably be able to get far more information.

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Do the Benefits Outweigh the Risks and the Practical Aspects of an Opt Out Program
Nothing in the world is all bad or all good. The smart grid is no exception. Intermingled in the web of problems are a few benefits. The question is, do these benefits outweigh the risks? We at MSMA, along with a rapidly increasing number of people in Maryland, feel they do not. Furthermore, many of the so called benefits of smart meters can be achieved by other means far simpler and without all the associated problems that smart meters present. BGE on page 1 of its April 6, 2012 comments claims that the smart grid will lead to reductions in energy use ; BGE states that its smart grid initiative will further the objectives of EmPOWER Maryland to achieve reductions in both peak demand and annual energy consumption. With TOU or Time of Use Meters, which are currently analog meters with a TOU addition, we would be able to shift our energy consumption to reduce peak loads safely. BGEs TOU program currently has three different rates: Peak, Intermediate, and Off Peak, similar to the land line phone service those of us over forty are well acquainted with. Telephone rates were higher during business hours. The rates went down at 5:00 pm and then again still further at 11:00 pm. Whenever possible, most people would plan their longer calls for evening hours, thus lessening peak load demand. Such a system could be implemented by the utilities with TOU analog meters and is eminently simple, free of health and privacy concerns, and would save energy, reduce peak load consumption, and further the objectives of EmPOWER Maryland. Pepco Claims on page 3 of its April 6, 2012 comments that ratepayers without smart meters will not be able to participate in new energy programs; Pepco stated that these AMI meters are needed for anyone to be able to participate in new energy savings programs. But the energy savings programs are designed by the utility. Any number of programs can be created that will encourage energy savings having nothing to do with smart meters. TOU meters could easily be used to develop alternative energy saving programs. Energy use can easily be monitored with safe cost effective technology that is readily available; Pepco claims on page 3 of its April 6, 2012 comments that seeing hourly and daily energy use on a timely basis makes it easier for customers to connect their actions with changes in energy use. The fact of the matter is that with a smart meter, we do not see our usage until 24-48 hours later. Smart meters do not provide real time data usage though the utilities like to give that impression. If we want real time energy usage, we would do better purchasing an energy monitor from Lowes for about $25. We dont need a smart meter for the delayed energy usage information it provides. BGE claims on page 13 of its April 6, 2012 comments that even a 1% opt out rate would jeopardize the system; In BGEs words,

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If customers were not required to contribute to the cost of opting-out, the opt-out rate could well exceed 1% and could seriously jeopardize the ability of the mesh communications network to perform to the point where it may be unworkable in certain areas But we are all paying for the smart grid with our taxes and utility rates. Recouping additional money from those who choose to opt out, as a crutch to keep an ailing, poorly planned business choice up and running is hardly reasonable and removes the element of choice from the consumer through coercion. Consumers need to assess the independent research and take measures to protect themselves if they so choose. Utilities need to manage the consequences of their own hasty business decisions. These two should not be interconnected. Protecting the integrity of the Smart Grid is not a justification for jeopardizing the safety and privacy of every man, woman and child in the BGE and PHI service areas. There is no need to create a new customer care, metering and billing system for those who choose to opt out; BGE claims on page 14 of it April 6, 2012 comments that an opt-out program would require it to change its customer care, metering and billing systems to maintain and manage opt-out customers and to assign charges associated with this option. But no change is really needed. MSMA as well as many others would be more than happy to continue with the current customer care, metering and billing systems. Instead, the utilities are going to need to develop new and costly customer care, metering and billing systems for their state of the art, cumbersome, new-fangled atypical meters. If the Commission allows opt outs, BGE plans to force new digital meters on those who opt out; BGE stated on page 11 of its April 6, 2012 comments that customers who elect to opt-out would be given BGEs current standard meter, which is a digital meter. A digital meter, even without the two way communication of a smart meter, still radiates RF. In addition, the Switching Mode Power Supply and other components of the meter, conduct transients onto the wiring of a customers home. Both of these are problematic to our health. (See Dirty Electricity, Electrification and the Diseases of Civilization, by Sam Milham MD, MPH) MSMA maintains that customers should be able to keep their safe analog meters. An independent auditor should establish the appropriate charges for opt out, not the utility; If the Commission decides to move forward with an opt-out program, BGE states on page 15 of its comments that it would seek to work with the Commission and other stakeholders to design a balanced opt-out program. While this sounds good, allowing the utility to set the appropriate charges would be like letting the fox guard the henhouse. MSMA is calling for an independent auditor, chosen by the rate payers, and paid for by the utilities, to assess what additional costs (or savings) an opt-out program would incur.

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Pepcos long laundry list of charges to those who chose to opt out; Pepco, on page 2 of its April 6, 2012 comments, talks about the costs it would incur for an opt out program: development of a system to track opt outs, IT system modifications, customer education material development [The list goes on] Maryland Smart Meter Awareness points out that if a decision is made to not have an opt out program, the people of Maryland would incur the following costs: 1) mandatory 24/7 exposure to an, as yet untested for safety, multilayered RF emitting infrastructure; 2) a system that, according to hacking expert, David Chalk, within three years has a "100% certainty of catastrophic failure; 3) a smart grid that the DOEs own Inspector General claims is vulnerable to cyber-attacks; and finally, a system that leaves us all susceptible to privacy invasion by amassing, storing, and transferring wirelessly our most personal data. Can the PSC really condone a system whose main benefits could be achieved in a far simpler manner, and whose cost to the people of Maryland is so potentially dangerous? MSMA believes that many Marylanders would choose to pass up high bill alerts, running bill totals, and a ping instead of a call (to detect remotely if power has been restored), for safety in their home.

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