Re: Hydro-Québec’s Application to Install a Wireless Electric Meter Network Across the Province, Request Number R-3770–2011 Mr. Jean-Paul Théorêt Chairman Régie de l’énergie du Québec 800 Place Victoria Montréal, Québec H3C 1E8 Dear Mr. Théorêt: I am writing to you to express my objections to and my deep concerns about the likely negative consequences of Hydro-Québec’s plan to install a wireless electric meter network across the Province of Québec. This plan is outlined in Hydro-Québec’s report entitled Projet lecture à distance, phase 1, which is available on the Régie’s website. I find myself wondering whether you are aware of the following facts. The installation of this invasive system of wireless meters is but a springboard for a hefty, province-wide increase in utility rates. In all likelihood, once the system is in place, HydroQuébec will implement a time-of-use, or heure juste, billing scheme that, in other jurisdictions, has often resulted in huge increases in electricity bills. For instance, in Ontario, over 80% of Hydro-One customers have seen an average increase of 150% in their bills, without any change in their consumption habits. Hydro-Québec’s plan is nothing more than a disguised rate increase and a cash grab. The wireless network that Hydro-Québec envisages relies on microwave radiation (GSM-900 microwaves) to transmit its data, a method that a growing body of independent scientific research indicates is harmful to human health, in particular, foetuses, infants, children, the sick, and the elderly. The scientific evidence of harm from man-made radiofrequency and microwave radiation is so convincing that, in a press release dated May 31, 2011, the International Agency for Research on Cancer (IARC), which is an agency of the World Health Organization, announced its decision to classify radiofrequency electromagnetic fields as “possibly carcinogenic to humans (Group 2B).” This classification applies, by extension, to microwave rediation, as well. While Hydro-Québec asserts that the level of microwave radiation emitted by its system would be far less than the exposure limits stipulated by Health Canada, many experts argue that these limits are based on the unproven and outdated assumption that radiofrequency and microwave radiation are harmless as long as they do not heat the body. In addition, these limits do not take into consideration the effects of chronic exposure to multiple sources of man-made electromagnetic radiation from cell phone towers, cell phones, cordless phones, baby monitors, leaking microwave ovens, iPads, iPods, Wi-Fi, and all the other wireless devices that now surround us. Given the recent decision by IARC to classify radiofrequency electromagnetic fields, and by implication all non-ionizing radiation, as a possible cause of cancer, it is probable that the World Health Organization will revise its current exposure limits on the permissible levels of the electromagnetic fields to which the public may be exposed. Since Health Canada has based its limits on those of the World Health Organization, it is foreseeable that the Canadian government will revise its exposure limits in the future, with the consequent possibility that the system Hydro-Québec intends to install would be rendered illegal. In its application to the Régie, Hydro-Québec stated that the electro-mechanical meters it currently uses have a useful life of 25 years. Unless its meters are of markedly inferior quality, their useful life can more accurately be projected at 40 years, whereas the wireless electronic meters that are to be installed can be expected to last a paltry 15 years. I object to the premature replacement of serviceable electro-mechanical meters as an unconscionable waste of money. I also question the validity of the decision to install meters that have such a short useful life. Hydro-Québec’s plan to install this wireless system, which will irradiate me and everyone else at times of the day imposed by the public utility, thereby threatening our health and well being, violates my personal right to choose how I will live my life. For this reason alone, this plan is unacceptable and should be rejected outright. Hydro-Québec’s new wireless system will greatly increase the amount of electromagnetic radiation in the environment. The system that is envisaged consists of individual digital meters installed on buildings whose signals are capable of travelling a distance of more than two kilometres. The meters are designed to transmit data to a system of repeaters that will in turn transmit to collectors, forming a Neighbourhood Area Network (NAN). The collectors will then transmit their data to Hydro-Québec’s computers, forming a Wide Area Network (WAN). The radiation from this extensive, complex, meshed system will be added to that emitted by cell phone towers, power lines, portable telephones, cell phones, Wi-Fi, and the like. I am worried about the possible repercussions that such a thick blanket of radiation could have on my health. Hydro-Québec’s estimate of data transmission time is misleading in that it takes into consideration only the time required to transmit the data related to energy consumption; the estimate ignores the total transmission time of the meter, which would be considerably longer. Hydro-Québec is also silent with regard to the frequency and duration of the transmissions that will be made by repeaters and collectors. Hydro-Québec’s plan could violate my personal security, despite the utility’s assertion that, because the transmitted data will be encrypted, it could not be stolen. Wireless systems are notoriously easy to hack into, which would keep Hydro-Québec always just one step ahead of would-be cyber thieves. The security-related costs would be astronomical, costs that are not associated with the current system of electro-mechanical meters. Hydro-Québec’s plan potentially violates my privacy because wireless electric meter systems are capable of collecting information that is superfluous to the efficient operation of an electric distribution system. In the initial phase, Hydro-Québec does not intend to gather detailed information about the energy consumption of residents, businesses, and industry. However, once the system is in place, it would be easy to expand the collection of data, which would be of extreme interest to industry. The sale of these data by Hydro-Québec, stripped of personal identifiers of course, could provide an additional and tempting source of revenue. I consider that the collection of this information would be a violation of my personal privacy, and I object to Hydro-Québec possibly subsidizing the market research activities of the private sector. Another reason that I object to the province-wide installation of a wireless meter system is that it is inordinately complex and, therefore, subject to sudden and catastrophic failure, which could increase the frequency and duration electricity black-outs. The software costs associated with the operation of such wireless systems are also inordinately high. Hydro-Québec’s plan is detrimental to Québécois society in that it would lead to the projected elimination of about 1,000 positions. Well-paying, secure jobs are fundamental to the economic health of a nation, in that individuals spend their money on lodging, food, clothing, transportation, heating, and other necessities and luxuries of life. The purchase of the extremely costly hardware and software required to operate a wireless electric meter system serves to enrich only the companies who manufacture these products. Finally, expected advances in technology will result in the development of data transmission methods that will not use radiofrequency or microwave radiation and will, therefore, be safe. These advances will soon render Hydro-Québec’s planned wireless electric meter system obsolete. What’s the hurry? I request that you share the arguments that I have made here with the eleven commissioners of the Régie and that you post my comments on your website under the heading “Observations.” Sincerely yours, c.c. Mr. Thierry Vandal, President and Chief Executive Officer, Hydro-Québec Isabelle Courville, Président, Hydro-Québec - Distribution Through Danielle Chabot - Media Relations (chabot.danielle.2@hydro.qc.ca) Mr. Clément Gignac (Minister responsible for Hydro-Québec) Minister of Natural Resources and Wildlife Government of Québec ministre@mrnf.gouv.qc.ca Dr. Yves Bolduc Minister of Health and Social Services Government of Quebec ministre@msss.gouv.qc.ca The Honourable Christian Paradis Industry Canada Government of Canada ministre.industrie@ic.gc.ca The Honourable Leona Aglukkaq Minister of Health Government of Canada leona.aglukkaq@parl.gc.ca Your Member of the National Assembly Government of Quebec (Email address available through http://www.assnat.qc.ca/en/deputes/index.html) Your Member of Parliament Government of Canada (See http://www.parl.gc.ca/MembersOfParliament/MainMPsCompleteList.aspx) Mailing Addresses Mr. Thierry Vandal President and Chief Executive Officer Hydro-Québec P.O. Box 11003, Succursale Centre-ville Montréal, Québec H3C 4T3 Ms. Isabelle Courville President, Hydro-Québec Distribution 75 René Lévesque Boulevard West Montréal, Québec H2Z 1A4 Mr. Clément Gignac Minister of Natural Resources and Wildlife Government of Québec 880, chemin Sainte-Foy, 10th Floor Québec, QuébecG1S 4X4 Dr. Yves Bolduc Minister of Health and Social Services Government of Québec Édifice Catherine-de-Longpré 1075, chemin Sainte-Foy, 15th Floor Québec, Québec G1S 2M1 The Honourable Christian Paradis Industry Canada - Government of CanadaHouse of Commons Parliament Buildings Ottawa, Ontario K1A 0A6 The Honourable Leona Aglukkaq Minister of Health - Government of Canada House of Commons Parliament Buildings Ottawa, Ontario K1A 0A6 Your Member of the National AssemblyThe Honourable __________ Member of Parliament Government of Canada House of Commons Parliament Buildings Ottawa, Ontario K1A 0A6 (No postage is required for mail sent to the House of Commons)