PSC chairman offers to brief lawmakers on electricity bidding process

By The Baltimore Sun


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Public Service Commission Chairman Kenneth D. Schisler offered to provide a confidential briefing to key legislators who have raised questions about the bidding process that resulted in the pending 72 percent increase in BGE electric bills.

Schisler made the offer to Senate President Thomas V. Mike Miller and House Speaker Michael E. Busch in response to questions they sent recently to officials at BGE and its corporate parent, Constellation Energy Group. Schisler said he wanted to assure them that the bidding process that resulted in the higher rates was fair and designed to produce the lowest possible prices for consumers.

Critics have questioned whether Constellation is making windfall profits by selling electricity to its corporate subsidiary, but Schisler said in his letter that a briefing will demonstrate that safeguards are in place to prevent such self-dealing.

"You are concerned that BGE affiliates might have received an unfair advantage in BGE's competitive solicitation.... In light of increases in purchase power costs, it is a legitimate question to ask," wrote Schisler, a former Republican delegate from the Eastern Shore who has come under fire for close relationships with utility lobbyists.

But, he added, the commission has "built numerous structural safeguards into the process to make it as near impregnable as any human process ever could be."

Schisler's offer would address one of several questions Miller and Busch asked last week. The Assembly's Democratic presiding officers also sought information about company finances and executive pay.

The legislators asked for answers by May 26. If they are not satisfied, Miller and Busch wrote, they could exercise the legislature's subpoena power to compel answers. The request from Miller and Busch was viewed by some lawmakers as a precursor to a possible special session of the Assembly to address electricity deregulation issues.

Schisler's letter included a nine-page primer on electricity bidding processes and the need for confidentiality in discussing proprietary information about such auctions.

Electricity prices are going up for BGE customers with the July 1 expiration of rate caps instituted as part of the 1999 deregulation of Maryland's electricity market.

As part of the deregulation plan, BGE was required to divest itself of its power plants, which it transferred to another part of Constellation. BGE now buys electricity on the open market and delivers it to customers through its power lines.

Under the terms of the plan, Constellation is allowed to sell the electricity it produces at the former BGE plants to BGE through competitive bidding.

A spokeswoman for Miller said he had not received the letter.

Miller, Busch and others in the legislature have argued for greater transparency in the setting of energy rates, and the city of Baltimore is suing the PSC in Circuit Court in an effort to get some of the same information. But Schisler argued in his letter that confidentiality in some matters is in the best interests of the public.

"The design of Maryland's... bid process requires a substantial amount of confidentiality around certain competitively sensitive information in order to protect customers from high prices and market manipulation," he wrote. "Without a certain level of protections for corporate proprietary information, potential bidders might shy away from the wholesale solicitation, thereby making the wholesale bidding process less competitive."

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It's CHEAP but not necessarily easy: Crosbie introduces PCs' Newfoundland electricity rate reduction strategy

Crosbie Hydro Energy Action Plan outlines rate mitigation for Muskrat Falls, leveraging Nalcor oil revenues, export sales, Holyrood savings, and potential Hydro-Quebec taxation to keep Newfoundland and Labrador electricity rates near 14.67 cents/kWh.

 

Key Points

PC plan to cap post-Muskrat rates by using Nalcor revenues, exports, and savings, with optional Accord funds.

✅ $575.4M yearly to hold rates near 14.67 cents/kWh

✅ Sources: Nalcor oil $231M, Holyrood $150M, rates/dividends $123.4M

✅ Options: export sales, restructuring, Atlantic Accord, HQ tax

 

Newfoundland and Labrador PC Leader Ches Crosbie says Muskrat Falls won't drive up electricity rates, a goal consistent with an agreement to shield ratepayers from cost overruns, if he's elected premier.

According to Crosbie, who presented the party's Crosbie Hydro Energy Action Plan — acronym CHEAP — at a press conference Monday, $575.4 million is needed per year in order to keep rates from ballooning past 14.67 cents per kilowatt hour.

Here's where he thinks the money could come from:

  • Hydro rates and dividends — $123.4 million
  • Export sales — $40.1 million
  • Nalcor restructuring — $30 million
  • Holyrood savings — $150  million
  • Nalcor oil revenue — $231 million

The oil money, Crosbie said, isn't going into government coffers but being invested into the offshore which, he said, is a good place for it.

"But the plan from the beginning around Muskrat Falls was that if there was need for it — for mitigation for rates — that those revenues and operating cash flows from Nalcor oil and gas would be available to be recycled into rate mitigation, as reflected in a recent financial update on the pandemic's impact. and that's what we're going to have to do," he said.

According to Crosbie, his numbers come from the preliminary stage of the Public Utilities Board process, even as rate mitigation talks have lacked public details.

This is a recent aerial view of the Muskrat Falls project in central Labrador. The project is more than 90 per cent complete, with first power forecast for late 2019, alongside Ottawa's $5.2B support for the project. (Nalcor)

"I'm telling you this is the best information available to anyone outside of government," he said. "We're working on what we can."

The PUB estimated Nalcor restructuring could save between $10 million and $15 million, according to Crosbie, but he figures there's "enough duplication and overpayment involved in the way things are now set up that we can find $30 million there."

Currently, provincial ratepayers pay about 12 cents per kilowatt hour as electricity users have started paying for Muskrat Falls costs.

Crosbie's $575.4-million figure would put rates at 14.67 cents per kilowatt-hour in 2021, where his plan pledges to keep them.

A recent Public Utilities Board Report says there's a potential $10 million to $15 million in savings from Nalcor, but Crosbie says he can find $30 million. (CBC)

"The promise is that Muskrat Falls, when it comes online — comes in service — will not increase your rates. Between now and when that happens there are rate increases already in the pipeline up to that level of [14.67 cents per kilowatt-hour] … so that is the baseline target rate at which rates will be kept.

"In other words, Muskrat will not drive up prices for electricity to consumers beyond that point."

In addition to those savings, Crosbie's plan outlined two further steps.

"We think it could be done out of the resources that I've just identified now, but if there's a problem with that, and as a temporary measure, we can use a modest amount of the Atlantic Accord review, fiscal review, revenues," he said.

 

Plan 'nothing new'

Premier Dwight Ball slammed the plan at the House of Assembly on Monday, saying it lacked insight.

"It was a copy and paste exercise," he told reporters. "There's nothing new in that plan. Not at all."

"We're not leaving any stone unturned of where the opportunity would be to actually generate revenue," he said.  "We are genuinely concerned about rate mitigation and we've got to get a plan in place."

 

Potential to tax Hydro-Québec

Crosbie also said there's potential to tax Hydro-Québec.

According to Crosbie, tax exemptions that expired in 2016 allow the province to tax exports from the Upper Churchill, which, he said, could result in "hundreds of millions or billions" in revenue.

"It's not my philosophy to immediately go and do that because that would generate litigation — who needs more of that? — but we do need to let Quebec know that we're very aware of that, and aware of that opportunity, and invite them to come talk about a whole host of issues," Crosbie said.

Crosbie said the tax would also have to be applied to domestic consumption.

"But so massive is the potential revenue from the Upper Churchill export that there would be ways to mitigate that and negate the effect of that on consumers in the province."

Crosbie said with the Atlantic Accord revenue, he could still present a balanced budget by 2022.

 

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Two huge wind farms boost investment in America’s heartland

MidAmerican Energy Wind XI expands Iowa wind power with the Beaver Creek and Prairie farms, 169 turbines and 338 MW, delivering renewable energy, grid reliability, rural jobs, and long-term tax revenue through major investment.

 

Key Points

MidAmerican Energy Wind XI is a $3.6B Iowa wind buildout adding 2,000 MW to enhance reliability, jobs, and tax revenue.

✅ 169 turbines at Beaver Creek and Prairie deliver 338 MW.

✅ Wind supplies 36.6 percent of Iowa electricity generation.

✅ Projects forecast $62.4M in property taxes over 20 years.

 

Power company MidAmerican Energy recently announced the beginning of operations at two huge wind farms in the US state of Iowa.

The two projects, called Beaver Creek and Prairie, total 169 turbines and have a combined capacity of 338 megawatts (MW), enough to meet the annual electricity needs of 140,000 homes in the state.

“We’re committed to providing reliable service and outstanding value to our customers, and wind energy accomplishes both,” said Mike Fehr, vice president of resource development at MidAmerican. “Wind energy is good for our customers, and it’s an abundant, renewable resource that also energizes the economy.”

The wind farms form part of MidAmerican Energy’s major Wind XI project, which will see an extra 2,000MW of wind power built, and $3.6 billion invested amid notable wind farm acquisitions shaping the market by the end of 2019. The company estimates it is the largest economic development project in Iowa’s history.

Iowa is something of a hidden powerhouse in American wind energy. The technology provides an astonishing 36.6 percent of the state’s entire electricity generation and plays a growing role in the U.S. electricity mix according to the American Wind Energy Association (AWEA). It also has the second largest amount of installed capacity in the nation at 6917MW; Texas is first with over 21,000MW.

Along with capital investment, wind power brings significant job opportunities and tax revenues for the state. An estimated 9,000 jobs are supported by the industry, something a U.S. wind jobs forecast stated could grow to over 15,000 within a couple of years.

MidAmerican Energy is also keen to stress the economic benefits of its new giant projects, claiming that they will bring in $62.4 million of property tax revenue over their 20-year lifetime.

Tom Kiernan, AWEA’s CEO, revealed last year that, as the most-used source of renewable electricity in the U.S., wind energy is providing more than five states in the American Midwest with over 20 percent of electricity generation, “a testament to American leadership and innovation”.

“For these states, and across America, wind is welcome because it means jobs, investment, and a better tomorrow for rural communities”, he added.

 

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Electric Cooperatives, The Lone Shining Utility Star Of The Texas 2021 Winter Storm

Texas Electric Cooperatives outperformed during Winter Storm Uri, with higher customer satisfaction, equitable rolling blackouts, and stronger grid reliability compared to deregulated markets, according to ERCOT-area survey data of regulated utilities and commercial providers.

 

Key Points

Member-owned utilities in Texas delivering power, noted for reliability and fair outages during Winter Storm Uri.

✅ Member-owned, regulated utilities serving local communities

✅ Rated higher for blackout management and communication

✅ Operate outside deregulated markets; align incentives with users

 

Winter Storm Uri began to hit parts of Texas on February 13, 2021 and its onslaught left close to 4.5 million Texas homes and businesses without power, and many faced power and water disruptions at its peak. By some accounts, the preliminary number of deaths attributed to the storm is nearly 200, and the economic toll for the Lone Star State is estimated to be as high as $295 billion. 

The more than two-thirds of Texans who lost power during this devastating storm were notably more negative than positive in their evaluation of the performance of their local electric utility, mirrored by a rise in electricity complaints statewide, with one exception. That exception are the members of the more than 60 electric cooperatives operating within the Texas Interconnection electrical grid, which, in sharp contrast to the customers of the commercial utilities that provide power to the majority of Texans, gave their local utility a positive evaluation related to its performance during the storm.

In order to study Winter Storm Uri’s impact on Texas, the Hobby School of Public Affairs at the University of Houston conducted an online survey during the first half of March of residents 18 and older who live in the 213 counties (91.5% of the state population) served by the Texas power grid, which is managed by the Electric Reliability Council of Texas (ERCOT). 

Three-quarters of the survey population (75%) live in areas with a deregulated utility market, where a specified transmission and delivery utility by region is responsible for delivering the electricity (purchased from one of a myriad of private companies by the consumer) to homes and businesses. The four main utility providers are Oncor, CenterPoint CNP -2.2%, American Electric Power (AEP) North, and American Electric Power (AEP) Central. 

The other 25% of the survey population live in areas with regulated markets, where a single company is responsible for both delivering the electricity to homes and businesses and serves as the only source from which electricity is purchased. Municipal-owned and operated utilities (e.g., Austin Energy, Bryan Texas Utilities, Burnet Electric Department, Denton Municipal Electric, New Braunfels Utilities, San Antonio’s CPS Energy CMS -2.1%) serve 73% of the regulated market. Electric cooperatives (e.g., Bluebonnet Electric Cooperative, Central Texas Electric Cooperative, Guadalupe Valley Cooperative, Lamb County Electric Cooperative, Pedernales Electricity Cooperative, Wood County Electric Cooperative) serve one-fifth of this market (21%), with private companies accounting for 6% of the regulated market.

The overall distribution of the survey population by electric utility providers is: Oncor (38%), CenterPoint (21%), municipal-owned utilities (18%), AEP Central & AEP North combined (12%), electric cooperatives (6%), other providers in the deregulated market (4%) and other providers in the regulated market (1%). 

There were no noteworthy differences among the 31% of Texans who did not lose power during the winter storm in regard to their evaluations of their local electricity provider or their belief that the power cuts in their locale were carried out in an equitable manner.  

However, among the 69% of Texans who lost power, those served by electric cooperatives in the regulated market and those served by private electric utilities in the deregulated market differed notably regarding their evaluation of the performance of their local electric utility, both in regard to their management of the rolling blackouts, amid debates over market reforms to avoid blackouts, and to their overall performance during the winter storm. Those Texans who lost power and are served by electric cooperatives in a regulated market had a significantly more positive evaluation of the performance of their local electric utility than did those Texans who lost power and are served by a private company in a deregulated electricity market. 

For example, only 24% of Texans served by electric cooperatives had a negative evaluation of their local electric utility’s overall performance during the winter storm, compared to 55%, 56% and 61% of those served by AEP, Oncor and CenterPoint respectively. A slightly smaller proportion of Texans served by electric cooperatives (22%) had a negative evaluation of their local electric utility’s performance managing the rolling blackouts during the winter storm, compared to 58%, 61% and 71% of Texans served by Oncor, AEP and CenterPoint, respectively.

Texans served by electric cooperatives in regulated markets were more likely to agree that the power cuts in their local area were carried out in an equitable manner compared to Texans served by commercial electricity utilities in deregulated markets. More than half (52%) of those served by an electric cooperative agreed that power cuts during the winter storm in their area were carried out in an equitable manner, compared to only 26%, 23% and 23% of those served by Oncor, AEP and CenterPoint respectively

The survey data did not allow us to provide a conclusive explanation as to why the performance during the winter storm by electric cooperatives (and to a much lesser extent municipal utilities) in the regulated markets was viewed more favorably by their customers than was the performance of the private companies in the deregulated markets viewed by their customers. Yet here are three, far from exhaustive, possible explanations.

First, electric cooperatives might have performed better (based on objective empirical metrics) during the winter storm, perhaps because they are more committed to their customers, who are effectively their bosses. .  

Second, members of electric cooperatives may believe their electric utility prioritizes their interests more than do customers of commercial electric utilities and therefore, even if equal empirical performance were the case, are more likely to rate their electric utility in a positive manner than are customers of commercial utilities.  

Third, regulated electric utilities where a single entity is responsible for the commercialization, transmission and distribution of electricity might be better able to respond to the type of challenges presented by the February 2021 winter storm than are deregulated electric utilities where one entity is responsible for commercialization and another is responsible for transmission and distribution, aligning with calls to improve electricity reliability across Texas.

Other explanations for these findings may exist, which in addition to the three posited above, await future empirical verification via new and more comprehensive studies designed specifically to study electric cooperatives, large commercial utilities, and the incentives that these entities face under the regulatory system governing production, commercialization and distribution of electricity, including rulings that some plants are exempt from providing electricity in emergencies under state law. 

Still, opinion about electricity providers during Winter Storm Uri is clear: Texans served by regulated electricity markets, especially by electric cooperatives, were much more satisfied with their providers’ performance than were those in deregulated markets. Throughout its history, Texas has staunchly supported the free market. Could Winter Storm Uri change this propensity, or will attempts to regulate electricity lessen as the memories of the storm’s havoc fades? With a hotter summer predicted to be on the horizon in 2021 and growing awareness of severe heat blackout risks, we may soon get an answer.   

 

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Australia PM rules out taxpayer funded power plants amid energy battle

ACCC energy underwriting guarantee proposes government-backed certainty for new generation, cutting electricity prices and supporting gas, pumped hydro, renewables, batteries, and potentially coal-fired power, addressing market failure without direct subsidies.

 

Key Points

A tech-neutral, government-backed plan underwriting new generation revenue to increase certainty and cut power prices.

✅ Government guarantee provides a revenue floor for new generators.

✅ Technology neutral: coal, gas, renewables, pumped hydro, batteries.

✅ Intended to reduce bills by up to $400 and address market failure.

 

Australian Taxpayers won't directly fund any new power plants despite some Coalition MPs seizing on a new report to call for a coal-fired power station.

The Australian Competition and Consumer Commission recommended the government give financial certainty to new power plants, guaranteeing energy will be bought at a cheap price if it can't be sold, as part of an electricity market plan to avoid threats to supply.

It's part of a bid to cut up to $400 a year from average household power prices.

Prime Minister Malcolm Turnbull said the finance proposal had merit, but he ruled out directly funding specific types of power generation.

"We are not in the business of subsidising one technology or another," he told reporters in Queensland today.

"We've done enough of that. Frankly, there's been too much of that."

Renewable subsidies, designed in the 1990s to make solar and wind technology more affordable, have worked and will end in 2020.

Some Coalition MPs claim the ACCC's recommendation to underwrite power generation is vindication for their push to build new coal-fired power plants.

But ACCC chair Rod Sims said no companies had proposed building new coal plants - instead they're trying to build new gas projects, pumped hydro or renewable projects.

Opposition Leader Bill Shorten said Mr Turnbull was offering solutions years away, having overseen a rise in power prices over the past year.

"You don't just go down to K-Mart and get a coal-fired power station off the shelf," Mr Shorten told reporters, admitting he had not read the ACCC report.

Energy Minister Josh Frydenberg said the recommendation to underwrite new power generators had a lot of merit, as it would address a market failure highlighted by AEMO warnings about reduced reserves.

"What they're saying is the government needs to step in here to provide some sort of assurance," Mr Frydenberg told 9NEWS today.

He said that could include coal, gas, renewable energy or battery storage.

Deputy Nationals leader Bridget McKenzie said science should determine which technology would get the best outcomes for power bills, with a scrapping coal report suggesting it can be costly.

Mr Turnbull said there was strong support for the vast majority of the ACCC's 56 recommendations, but the government would carefully consider the report, which sets out a blueprint to cut electricity bills by 25 percent.

Acting Greens leader Adam Bandt said Australia should exit coal-fired power in favour of renewable energy to cut pollution.

In contrast, Canada has seen the Stop the Shock campaign advocate a return to coal power in some provinces.

The Australian Energy Council, which represents 21 major energy companies, said the government should consult on changes to avoid "unintended consequences".

 

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Electricity complaints filed by Texans reach three-year high, report says

Texas Electricity Complaints surged to a three-year high, highlighting Public Utility Commission data on billing disputes, meter problems, and service issues in the competitive retail electricity market and consumer protection process.

 

Key Points

Consumer filings to Texas PUC about billing, service, and meters, with 2018 reaching a three-year high.

✅ 5,371 complaints/inquiries in FY2018; 43.8% involved billing disputes.

✅ Service issues 15.8% and meters 12.6%; PUC publishes complaint stats.

✅ Advocates urge monitoring to keep deregulated retail market healthy.

 

The number of electricity service-related complaints and inquiries filed with the state’s Public Utility Commission reached a three-year high this past fiscal year, an advocacy group said Tuesday.

According to the Texas Coalition for Affordable Power, a nonprofit that advocates for low electricity prices, Texans filed 5,371 complaints or inquiries with the commission between September 2017 and August of this year. That’s up from the 4,175 complaints or inquiries filed during the same period in 2017 and the 4,835 filed in 2016. The complaints and inquiries included concerns with billing, meters and service.

“This stark uptick in complaints is disappointing — especially after several years of generally improving numbers,” Jay Doegey, the coalition's executive director, said in a written statement. “In percentage terms, the year-to-year rise in complaints is the greatest in a decade. Clearly, many Texans remain frustrated with aspects of their electric service.”

The utility commission did not immediately respond to a request for comment.

While complaints and inquiries increased in 2018, the number of complaints and inquiries has generally decreased since 2009, when Texans filed 15,956 with the commission. That could be because there have been lower residential electricity prices and because Texans have become more familiar with the state’s competitive retail electricity system over the last decade, the coalition's report said.

And complaints from 2018 are well below 2003 levels, when the number of complaints and inquiries soared to more than 17,000, a year after Texas deregulated most of its electricity market structure at the time.

But Jake Dyer, a policy analyst at the coalition, said his group is closely watching the uptick in complaints this year as the Texas power grid faces recurring strains.

“We are invested in making sure the competition works,” Dyer said. “When you see an uptick like this, you should watch very closely to make sure the market remains healthy and to make sure there is not something else going on.”

However, Dyer said that it is too early to know what that something else that is going on might be.

According to the report, concerns about billing made up most of the complaints and inquiries filed this year at 43.8 percent. That’s up from 42.5 percent in fiscal year 2017. Concerns about the provision of electrical service and about electrical meters also ranked high, constituting 15.8 percent and 12.6 percent of the complaints and inquiries, respectively.

The Public Utility Commission publishes customer complaint statistics on its website. The Texas Coalition for Affordable Power takes into account both complaints and inquiries filed with the commission for its report in order “to gauge general consumer sentiment and to maintain a uniform methodology across the study period.”

Texans can file an official complaint with the the commission's Customer Protection Division. Under the complaint process, the complaint is sent to the electric company, which has 21 days to respond.

Some providers outside the competitive market, such as electric cooperatives, drew praise for performance during the 2021 winter storm.

Following the 2021 winter storm, Texas lawmakers proposed an electricity market bailout to stabilize costs and reliability.

 

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Duke Energy installing high-tech meters for customers

Duke Energy Smart Meters enable remote meter reading, daily energy usage data, and two-way outage detection via AMI, with encrypted data, faster restoration, and remote connect/disconnect for Indiana customers in Howard County.

 

Key Points

Advanced meters that support remote readings, daily usage insights, two-way outage detection, and secure, encrypted data.

✅ Daily energy usage available online the next day

✅ Two-way communications speed outage detection and restoration

✅ Remote connect/disconnect; manual reads optional with opt-out fee

 

Say goodbye to your neighborhood meter reader. Say hello to your new smart meter.

Over the next three months, Duke Energy will install nearly 43,000 new high-tech electric meters for Howard County customers that will allow the utility company to remotely access meters via the digital grid instead of sending out employees to a homeowner's property for walk-by readings.

That means there's no need to estimate bills when meters can't be easily accessed, such as during severe weather or winter storms.

Other counties serviced by Duke Energy slated to receive the meters include Miami, Tipton, Cass and Carroll counties.

Angeline Protogere, Duke Energy's lead communication consultant, said besides saving the company money and manpower, the new smart meters come with a host of benefits for customers enabled by smart grid solutions today.

The meters are capable of capturing daily energy usage data, which is available online the next day. Having this information available on a daily basis can help customers make smarter energy decisions and support customer analytics that avoid billing surprises at the end of the month, she said.

"The real advantage is for the consumer, because they can track their energy usage and adjust their usage before the bills come," Protogere said.

When it comes to power outages, the meters are capable of two-way communications. That allows the company to know more about an outage through synchrophasor monitoring, which can help speed up restoration. However, customers will still need to notify Duke Energy if their power goes out.

If a customer is moving, they don't have to wait for a Duke Energy representative to come to the premises to connect or disconnect the energy service because requests can be performed remotely.

Protogere said when it comes to installing the meters, the changeover takes less than 5 minutes to complete. Customers should receive advance notices from the company, but the technician also will knock on the door to let the customer know they are there.

If no one is available and the meter is safely accessible, the technician will go ahead and change out the meter, Protogere said. There will be a momentary outage between the time the old meter is removed and the new meter is installed.

Kokomo and the surrounding areas are one of the last parts of the state to receive Duke Energy's new, high-tech meters, which are commonly used by other utility companies and in smart city initiatives across the U.S.

Protogere said statewide, the company started installing smart meters in August 2016 as utilities deploy digital transformer stations to modernize the grid. To date, they have installed 694,000 of the 854,000 they have planned for the state.

The company says the information stored and transmitted on the smart meters is safe, protected and confidential. Duke Energy said on its website that it does not share data with anyone without customers' authorization. The information coming from the meters is encrypted and protected from the moment it is collected until the moment it is purged, the company said.

Digital smart meter technology uses radio frequency bands that have been used for many years in devices such as baby monitors and medical monitors. The radio signals are far below the levels emitted by common household appliances and electronics, including cellphones and microwave ovens.

According to the World Health Organization, FCC, U.S. Food and Drug Administration and Electric Power Research Institute, no adverse health effects have been shown to occur from the radio frequency signals produced by smart meters or other such wireless networks.

However, customers can still opt-out of getting a smart meter and continue to have their meter manually read.

Those who choose not to get a smart meter must pay a $75 initial opt-out fee and an additional $17.50 monthly meter reading charge per account.

If smart meters have not yet been installed, Duke Energy will waive the $75 initial opt-out fee if customers notify the company they want to opt out within 21 days of receiving the installation postcard notice.

 

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