Linked comments were submitted 11 April 2014 in opposition to the MPUC Examiners’ Report on “smart” meter safety (read about that report here). Technically, comments should be based on the case record and (in also laying grounds for appeal) should point out and discuss, for the most part, errors of law and fact. A few excerpts from the Complainants’ Comments follow here:
The Examiners’ Report should be rejected by the commission for several reasons. Most fundamentally, the report fails to decide the discrete issue the Maine Law Court directed the commission to resolve, that is, whether CMP’s smart meters pose a credible risk of harm. The report thereby fails to satisfy the commission’s statutory mandate to ensure safety.
The report also applies the wrong standard of proof and does so in a manner that effectively shifts the burden of proof to complainants. To the extent the report evaluates record evidence on the question of safety, it discusses primarily whether complainants have produced sufficient evidence to prove causation of harm, as opposed to whether CMP has produced sufficient evidence to prove there is no credible threat of harm.
And the brief conclusion:
For the foregoing reasons, complainants take exception to the Examiners’ Report and urge the MPUC to determine that: 1) CMP has failed to prove there is no credible threat of harm from its “smart” meter technology; and 2) safety cannot be ensured without remedial measures, the scope of which may need to be determined in a separate proceeding.
Read the full Complainants’ Comments here, as well as these filings: Citizens for Health Comments and Dianne Wilkins’ Comments.
—Ed Friedman, 11 April 2014