Tuesday, February 15, 2011

Smart Grid Bill of Wrongs



The Naperville Smart Grid Customer Bill of Rights (NSGCBoR) is one of those government promises that seems so reasonable, so well-intentioned, that no reasonable person could oppose it, when in reality it is an exercise in naivety and public relations, that no reasonable person can put any faith in.

First and foremost, a true Bill of Rights would be accompanied by penalties for violations of those rights.  Yet there are no penalties whatsoever in the proposed ordinance.  If the city violates the privacy rights of citizens, what happens?  Nothing.  If the city doesn't honor its promise to give citizens the right to make their own choices over the time and manner of their personal power consumption, what happens?  Nothing.  The Watchman challenges the city Council to include such penalties.  He doubts the city will do so because any such penalties would be levied against the city itself.  How about compensation for citizens whose rights are violated?  Those provisions are absent as well.

This ordinance is a paper tiger.  It can be ignored any time the city wants with no repercussions for the city.  Sure, you can make a complaint to the Public Utility Board (PUB), but that board has only met once in the last year and a half.  Maybe the board's acronym (PUB) explains why they don't meet very often, or perhaps it explains where they meet.  So highly regarded is the PUB that it has not been consulted for advice in drafting or overseeing the Smart Grid Initiative... ever.  Why should the public believe that board can be an effective arbiter of complaints?

But that's okay because the ordinance is so vague that the city could never be found in violation of it. Key terms such as "convenient access", "available through multiple channels", "convenient user interface", and "clear and transparent manner"beg for further clarification yet there is none in the ordinance.  What constitutes convenient access?  Who decides if the city is being clear and transparent?  Maybe the PUB can help sort it out.  Oh, wait...

There are a few bold promises in the NSGCBoR.  "The city will never ration electricity."  That should be comforting, right?  Let me tell you fellow citizens, once the city has the capabilitity to set electricity rates on a per device basis in your home, they can ration your electricity usage, just based on price.  They can say that electric lights have a base rate of X, while air conditioning has a rate of 100X. You will sure feel like your electricity is being rationed when you can't *afford* to have as much as power as you need, powering the device that you need, at the time that you need it.  It will be de facto electricity rationing.

"Wait, wait, wait," says the NSGCBoR, "Customers can select a billing rate structure that meets your needs. This includes the traditional fixed-rate pricing and time of use pricing programs. Customers will have the ability to change programs."  Here again, all the city has to do is set the "time of use pricing" to be X and the "traditional fixed-rate pricing" to 100X and you will drop the traditional fixed-rate pricing model like a live wire on a wet floor.  Once the city can use price to control when, where, and how you use electricity, they will have too much control of your life.

Whatever rights the NSGCBOR is alleged to confer are as ephemeral as a summer breeze and about as powerful. The ordinance is so vague as to be meaningless.  Worse, it gives citizens the impression that they have rights, which they most certainly do not.  The Watchman encourages you to read this ordinance, alongside of other existing city ordinances, and you will see quite clearly that it was written by a PR firm and not by legislators or regulators.  There was no public input into this so-called Bill of Rights.

The entire Smart Grid Initiative continues to roll on with virutally no public support.  Pretty much like Congress with healthcare.

But far be it from the Watchman to be only a naysayer.  The NSGCBoR would have real teeth if it included a provision that disallowed differences in electricity rates between traditional fixed-price models and time-specific or device-specific models of more than, say, 1%.  Is 1% the right number?  I don't know.  But the city should have the courage to pick a number, present it to the public, and live by it.

Plug into choice?  Really??  Only if your idea of choice is turning your decision making over to the city.


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