20230328Formal Complaint.pdf

RECEIVED
Tuesday, March 28, 2023 11:37:24 AM
IDAHO PUBLIC
UTILITIES COMMISSION
CASE NO. PAC-E-23-07
Jan Noriyuki, Commission Secretary
Idaho Public Utilities Commission
PO Box 83720
Boise, ID 83720-0074
Date: March 24, 2023
From: Karen Lane
PO Box 362
Rigby, ID 83442
FORMAL COMPLAINT
RE: Installation of "Smart1' Meter and threat of service disconnection
Dear Ma'am,
This FORMAL COMPLAINT is a follow-up to an initial complaint which i, Karen Lane submitted to Idaho
Public Utility Commission on March 20,2023. I have received from Rocky Mountain Power a FINAL
NOTICE of intent to terminate service on March 27, 2023. Rocky Mountain's notice claims that we have
refused access to the meter. On the contrary, we solemnly affirm that at no time has access to the
meter been denied, and the claim by Rocky Mountain Power that we have is knowingly and intentionally
false. To be clear: at no time have we prevented Rocky Mountain Power from accessing the existing
meter attached to our home for any purpose, and our account is paid in full and up to date.
What we have done is require that the meter--which is attached to our house--remain a meter that does
not emit radio wave frequencies. We have concerns about such meters, on physical health grounds as
well as legal privacy concerns. To date, Rocky Mountain has refused to address the issue or enter into a
dialogue with us in good faith. Instead, Rocky Mountain Power has resorted to bullying and strong-arm
techniques to try to force us to accept a so-called "smart meter" attached onto our private property
without our consent.
However, having objections to installation of a particular type of meter, a so-called "smart meter," is
NOT legal grounds for disconnecting our current electrical service. This is crucial legal fact that has been
ignored both by Rocky Mountain Power and by Idaho Public Utilities Commission's Utilities Compliance
Investigator, Chris Hecht, who cited Electric Service Regulation No. 6 as Rocky Mountain Power's
authority to threaten to terminate our electrical service.
Electric Service Regulation No. 6 says, "The Customer shall provide safe, unencumbered access to
Company's representatives at reasonable times, for the purpose of reading meters, inspecting,
repairing, or removing metering devices and wiring of the Company." We have done precisely that. At
no time have we denied access to the meter. As we have always provided the required access, neither
Electric Service Regulation No. 6 nor IDAPA 31.21.01, Rule 302.01.e apply to our case, and Rocky
Mountain Power does not have legal authority to terminate our electrical service on those grounds.
If there is a law or regulation that specifically authorizes termination of electrical service for objecting to
the installation of a smart meter in the place of an analog meter, we respectfully request that it be
shown to us. Otherwise, because we have never denied access to the meter, we respectfully request
that the Idaho Public Utilities Commission intervene to prevent Rocky Mountain Power from unlawfully
disconnecting our electrical service and to require Rocky Mountain Power to engage in respectful, good
faith dialogue with us about an acceptable solution that addresses our concerns.
Respectfully,
Karen Lane
The foregoing instrument was acknowledged before me on this __ p _ _,_;_·:;2._z_?_z..8_~ _____ by
DANIEL PECK
COMMISSION NUMBER 62322
NOTARY PUBLIC
STATE OF IDAHO
Signature of Notary Publi~--~ 2