Papazian & Mead, PLC

2141 E. Highland Avenue, Suite 105

Phoenix, AZ 85016

Frank R. Mead


P: (602) 620-1449

F: (602) 606-8300


April 25, 2012

By US Mail


Arizona Corporation Commission

Docket Control

1200 W. Washington St.

Phoenix, Arizona 85007


            Docket # E-00000C-11-0328 – Smart Meters

            Re:  How often wireless smart meters actually transmit


Dear Commissioners:


During the March 23rd hearing, one Arizona Utility stated that it only receives transmissions 14 times a day from each of their smart meters. Another Utility stated that they receive data every 15 minutes. These are low-end numbers, and not representative of the current technologies. As evidenced by the September 8, 2011 hearing when Tucson Electric/Unisource disclosed that their AMR meters transmit every 30 seconds, or 2880 times a day.


There have been complaints in other states that utilities there did not fully disclose how often their meters actually transmit. Some utilities were apparently only stating how often they read their meters, but omitted other types of transmissions. From a human health perspective, the informational content of a wireless transmission is irrelevant. It is the actual act of transmission that matters. Otherwise, there is no distinction.


Following these complaints, on October 18, 2011 Administrative Law Judge Yip-Kikugawa directed the three largest California utilities to make specific and detailed disclosures. The response from Pacific Gas & Electric is enclosed.


In Table 2-1 of the response, it is stated that each meter is read six times a day. However, the total number of transmissions from each meter is typically 10,000 a day, or once every 8.6 seconds.


The PG&E system is a “mesh network” where some of the meters act as relay stations. These meters can transmit much more often. According to PG&E’s Table 2-1 (right side), they may transmit as often as 190,000 times a day or about twice a second. It is not possible to know which of the meters serve as relays, and it may change over time which of them does. Mesh networks are state of the art and are being deployed by many utilities, including utilities in Arizona.


Therefore, the public health is best served by limiting these transmissions as much as possible, especially since most, if not all, of the desired goals can be accomplished with much less.


However, we must stress that limiting the transmissions is not a viable alternative to a medical opt-out for people with electrical hypersensitivities. People with EHS must be allowed to have a non-communicating electromechanical meter. There is no other choice.


Submitted on behalf of:


Safer Utilities Network

P.O. Box 1523

Snowflake AZ 85937



Enclosed (1): Pacific Gas and Electric Company’s response to Administrative Law

Judge’s October 18, 2011 Ruling Directing it to File Clarifying Radio Frequency

Information (pages 1 and 5 only)