Rather than the road to hell being paved with good intentions, I suggest that the road to hell is paved with unexamined assumptions. In the case of RI Energy/PPL's proposal before the RI Public Utilities Commission to deploy AMF (Advanced Metering Functionality, i.e. "Smart" Meter) infrastructure in all RI homes and businesses beginning next year, I assert that there are three unexamined assumptions in RI Energy's business plan (which includes their benefit/cost analysis), that when examined, require rejection of the plan.

I participated in person at the RI PUC Public Hearing on April 4, 2023 on this Docket (NO. 22-49-EL: in re: The Narragansett Electric Co. d/b/a RI Energy Advanced Metering Functionality Business Case and Cost Recovery Proposal), I have submitted written testimony in the Docket, watched some of the Technical Hearings, and watched all five days of the Evidentiary Hearings via the livestream. I have admiration for the thoughtfulness and perseverance with which Chair Gerwatowski, the other two RI PUC Commissioners, as well as Commission staff have asked probing questions of RI Energy/PPL's witnesses. There is no doubt that the RI PUC is sincerely doing its due diligence to assure that RI ratepayers and residents will benefit from the massive undertaking that such an infrastructure deployment would entail. I also have no doubt that the employees and witnesses for RI Energy/PPL are sincerely doing their utmost to provide what is in their view a safe and reliable system for facilitating and monitoring RI's electric energy use. This is a truly complex issue, addressing RI's electric energy needs now and into the future. Yet, the entire discussion during the RI PUC sessions, though detailed and certainly deeply considered, takes place with crucial blinders on. Therefore, I am opposed to this plan, and believe that it is a losing proposition for Rhode Island.

There are three glaring assumptions that need to be addressed and have not been during the many long hours of question and answer sessions. However, these three assumptions have been addressed in the numerous oral and written testimonies submitted to the RI PUC in this Docket, including an APRA (Access to Public Records Act) request that I made, along with Sam Parish, a forensics engineer, and Stephen Dahl, Director of Rhode Islanders for Safe Technology and Director of the Toxics Information Project. All of the written public testimony, including the APRA request and response, can be found at this link: https://ripuc.ri.gov/Docket-22-49-EL The video recording of the April 4, 2023 Public Hearing can be found at this link: https://video.ibm.com/recorded/132693444

1. RI Energy has presented no documentation to the RI PUC that RI Energy/PPL has commissioned an independent engineering review of fire and/or safety issues with the proposed meter replacement plan. Meters sold by Landis + Gyr, the company that RI Energy has chosen to sell meters to RI, have been implicated in house fires, even those with the UL label.
2. RI Energy provides reassurances to its customers that the RF (radiofrequency/microwave radiation) emitted from these "Smart" Meters is so low-level that it can have no negative impact on health. This is in the face of thousands of scientific/medical articles in peer-reviewed, non-industry funded journals that establish not only that this radiation is biologically harmful, but also that is has already been harming people, wildlife, pollinators, plants, and trees for many years.
3. RI Energy continues to claim that the AMF meters have a useful lifespan of 15-20 years. This is the same claim that most utility companies make to convince Public Utility Commissions that their benefit/cost analysis provides a reasonable expectation of benefit. Yet, these meters are essentially computers. They are subject to temperature extremes, humidity, and other environmental factors, as well as the need to upgrade software. What computer has survived 15-20 years?

The RI Public Utilities Commission is currently deliberating on a response to RI Energy/PPL's proposal to deploy AMF infrastructure across RI. Rhode Island ratepayers and all residents need assurance that the RI PUC is examining these three assumptions and will make a decision that is protective of RI ratepayers financially, and of all Rhode Islanders with regard to their health and safety. That decision should be a NO to RI Energy's proposal.

Sheila Resseger, co-founder of 5G Free RI is a board member of Toxics Information Project and a retired teacher for the RI School for the Deaf.