California American Water Company to roll-out Smart water meters; proposes analog opt-out — public hearings scheduled

California American Water Company (Cal-Am) is requesting authorization from the California Public Utilities Commission to roll-out Smart/AMI water meters in two service areas – the Ventura District and the Central District (Monterey County) — Application 19-07-004.

Cal-Am also proposes an opt-out program that would install an analog non-digital meter in place of the AMR or AMI water meters. They propose these opt-out fees:

$70. initial fee, and
$13. per month

The $70. fee would only apply if Cal-Am has to install an analog meter. If an analog meter is still in place, the customer would not be charged the $70.

The Ventura and Central Districts currently have pilot AMI meter programs, and Cal-Am states that the Central District program is an opt-in program.

In this CPUC application, Cal-Am also wants to raise water rates in its service territory and to change certain CPUC requirements for the company.

CPUC Commissioner Genevieve Shiroma, the assigned commissioner for this proceeding, did not include the opt-out proposal in her scoping memo of the issues to be resolved in the proceeding (see pages 4-8). A CPUC spokesman told me that the opt-out is not being considered by the Commission, and that the public needs to raise it during the public participation hearings before the Administrative Law Judge to make sure it is included.

A few other relevant issues in the scoping memo include:

4. Evaluate the adequacy of Cal-Am’s Customer Service.
5. Evaluate whether Cal-Am follows all statutory and regulatory requirements.
7. Whether there are any safety issues which the Commission needs to address.

Cal-Am does not mention ADA accommodation in relation to its AMI/AMR wireless water meters. An ADA accommodation of receiving an analog meter is not an opt-out, and under the ADA, opt-out fees would be considered surcharges and are not allowed. It is not meter “choice” when a person’s medical condition or disability requires them to have an analog meter.

The California Public Utility Commission is holding these public participation hearings in Cal-Am’s service territory. The public is invited to attend and comment at these hearings, and you can submit additional written information into the record there: 

December 3, 2019 – Larkfield at 6:00 p.m.
Luther Burbank Center for the Arts
50 Mark West Springs Rd
Santa Rosa, CA 94503

January 9, 2020 – Imperial Beach at 6:00 p.m.
Imperial Beach Council Chambers
825 Imperial Beach Blvd
Imperial Beach, CA 91932

January 14, 2020 – Sacramento 6:00 p.m.
2729 Prospect Park Drive
Rancho Cordova, CA 95670

January 29, 2020 – Duarte at 6:00 p.m.
Courtyard by Marriott
700 West Huntington Dr
Monrovia, CA 91016

January 30, 2020 – Ladera Heights at 6:00 p.m.
Los Angeles Public Library – Baldwin Hills Branch
2906 S. La Brea Ave
Los Angeles, CA 90016

February 3, 2020 – Camarillo 6:00 p.m.
Camarillo Library Community Room
4101 Las Posas Road
Camarillo, CA 93010

February 4, 2020 – Thousand Oaks 1:00 p.m. and 6:00 p.m.
Thousand Oaks Grant Brimhall Library
1401 E. Janas Road
Thousand Oaks, CA 91362

February 18, 2020 – Seaside 6:00 p.m.
Seaside Council Chambers
440 Harcourt Ave.
Seaside, CA 93950

February 19, 2020 – Gonzales 6:00 p.m.
Gonzales Council Chambers
117 Fourth St.
Gonzales, CA 93926

To send comments to the CPUC (considered “informal comments”), to learn how to participate in the proceeding, or if you have other questions about the proceeding and hearings, contact the Public Advisors’ Office:
505 Van Ness Ave.
San Francisco, CA 94102

The CPUC Public Advocates Office will submit their own testimony based on the public comments at the hearings, but their testimony is due February 14, before the only two hearings in the Central District – a district slated to get the Smart Meter roll-out (p. 9, Footnote 6). Shiroma said in her scoping memo

If Public Advocates wishes to provide a supplement to its testimony following the Seaside PPH, arrangements will be made to allow this. Public Advocates shall advise the ALJ at the conclusion of the Seaside PPH if it desires to provide a supplement to its testimony based on comments received at the Seaside PPH.

This is clearly inadequate, and  Comm. Shiroma doesn’t mention the Chualar/Gonzales PPH at all. The Public Advocates’ testimony must take in the complete record of public participation from all the hearings, with sufficient time for them to process that record.

Cal-Am has been installing Neptune R900 AMI smart water meters (see also this article) in the Central district and may be installing them throughout their service territory. These meters have powerful 1-watt pulses every 7 ½ minutes for AMI small cell node collection, in addition to constant 100 mW pulses for AMR data collection.

Water meters are often installed in the public rights of way — in sidewalks and next to streets – and interfere with access for those who are disabled by electromagnetic sensitivity.

The just-released bee study provides additional evidence that the EMF emissions of these meters have considerable penetration into the bodies of bees. Wildlife and humans are impacted as well. The move to install Smart Meters in more communities is very unwise.

Cal-Am’s divisions and/or districts are currently the Northern Division (including Sacramento and Larkfield), Central Division, Monterey Wastewater, Los Angeles County, San Diego County and Ventura County.

American Water Works Company is the parent company of California American Water Company.

Commissioner Shiroma was Ward 4 Director on the Sacramento Municipal Utility District (SMUD) board from 1999 – 2018, and was appointed to the CPUC by Gov. Newsom in 2019.

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