This paper has become one of the highest ranked resources on the web addressing Smart Meter interference problems. This article has been updated to incorporate new research.
Chatham-Kent Energy has recently installed a number of Smart Meters, with the goal of having all 32,000 customers serviced by these devices prior to the December 31, 2010 provincial deadline. Chatham-Kent Energy has been noticed within the industry as taking a lead while at the same time reducing costs considerably, claiming other utilities are looking to emulate this success.
The total cost of introducing Smart Meters is estimated at $4,638,425, including the TUNet modules used inside the meters. This is funded by Hydro customers.
While we must applaud the Smart Meter initiative, and be proud of our leading role in introducing this technology, there are some serious concerns based on the technical aspects of the implementation. It may be that the money we are saving now with the current scheme could end up being wasted, and the other utilities that looked to Chatham-Kent for leadership might wish they hadn’t. Specifically, the method of returning data from these meters to the billing system utilizes a wireless radio telemetry system, and of the many systems available, one of the most inappropriate ones was chosen.
Herein lies the cause for concern, which could help explain why the project is costing only a third of the costs faced by other utilities. This would be a fair time to assess the present implementation and consider its impact on the community in general and the ratepayers who will ultimately pick up the tab for correcting any problems caused by improperly designing a system based on a misinterpretation of Industry Canada rules.
Smart Meters collect electricity usage throughout the day for each customer, and periodically transmit this data via radio back to the billing system so the customer can be charged the appropriate rate based on the time of day. This radio system requires the use of the electromagnetic frequency spectrum to function, which is a precious and congested natural resource.
Several bands of frequencies and data methods are available for this purpose, each with its own rules, advantages and disadvantages. The Ontario Energy Board listed several options, with pros and cons. In Chatham-Kent, the system has been designed to utilize the band of frequencies from 902-928 MHz, with a spread-spectrum or frequency-hopping modulation method. This is rated as a weaker choice. Technical information about this band, as provided by Industry Canada, follows.
|Industry Canada has allocated this band to Radiolocation as the Primary user, with the Amateur Radio Service being granted access as a Secondary user on the basis of causing no interference to the Primary user. As it happens, the Radiolocation services using this band are limited to shipborne radar on maritime coastal waterways. Consequently, the Secondary user is in no danger of causing prohibited interference to the Primary user in the Southern Ontario area, permitting full unrestricted Amateur use. This band is rather unusual in that, in addition to the official users, low-power licence exempt equipment is permitted as long as certain technical guidelines are followed. Typically, these radio devices use extremely low power to transmit signals very short distances of less than a hundred feet. Such unlicenced and licence-exempt equipment is permitted on a shared use, unprotected basis. That is, the frequencies have to be shared with the other users, and users are not allowed to cause interference to each other, nor to the official users of the band as allocated. All equipment must be certified by Industry Canada. Even though the regulations prohibit these devices from causing interference, licence-exempt equipment MUST accept any and all interference caused to the device, even if it results in undesirable operation. This band plan is based on mutual respect and cooperation amongst the permitted users. It is important to note that Industry Canada DOES NOT intervene in any cases of interference amongst unlicenced and licence-exempt users.
Examples of licence-exempt equipment operating on the 902-928 MHz band are: cordless phones, crib monitors, wireless headphones, patio speakers, remote controls, wireless microphones, security systems, motion detectors, garage door openers, remote car starters, wireless computer networks – essentially any cordless electronic equipment as might be found in thousands of local homes, businesses and churches. Much of this equipment permits the user to change the channel used to prevent interference to a neighbour using the same device, as such interference would be illegal. In addition, the low power and small bandwidth required by any individual user permits a multitude of devices to co-exist, as they have in Chatham-Kent until now. Chatham-Kent Hydro monopolized the whole band so there are no free channels for anyone else.
The Smart Meters installed by Chatham-Kent Hydro utilize an unlicenced radio transmitter operating on the 902-928 MHz band to convey data back to the billing system. Based on technical data supplied by Chatham-Kent Hydro, supplemented by further investigation, it appears that this band was chosen based on a misunderstanding of the rules governing this band. Each meter installed collects electricity usage data by the customer, and periodically sends this data back to the Chatham-Kent Hydro billing system using radio telemetry. These meters contain a small radio transmitter, in this case a TUNet module. The transmitter operates as a licence-exempt device under RSS-210 of the Radiocommunication Act. Although some of the technical information regarding these devices could not be revealed, citing patent protection, it is very easy to determine how they work by decompiling the regulations governing them.
To qualify for licence-exempt use in the 902-928 MHz band, equipment transmitter power must not exceed 50 millivolts/meter at a distance of 3 meters. This corresponds to an output power of 0.75 milliwatts, or 0.00075 watts. Since the TUNet modules transmit significantly higher power levels of 0.5 watts of RF energy, they must operate under Annex 8 of RSS-210, utilizing a spread-spectrum or frequency hopping scheme. As data is being transmitted, the transmitter frequency must “hop” through a pseudo-random sequence of channels, remaining on any individual channel for no more than 0.4 seconds. Based on the 0.5 watts power of the TUNet module, we can conclude that each unit must utilize at least 50 channels in the sequence to be legal. Since Annex 8 of RSS-210 prohibits the use of any type of synchronization, there must be significant redundant transmission of data to compensate for data lost due to collisions with other Smart Meters, noise, or interference. The system may use intelligence to avoid using a frequency occupied by a shared user of the band, but it must never be coordinated to prevent collisions with itself. The modulation of an individual frequency using 50 channels must be less than 250 kHz. The receiver is also expected to comply with the requirements of RSS-210.
Smart Meters Cause Illegal Interference
This implementation is unwise for a number of reasons.
Much consumer equipment exists in this band. Early tests indicate that most of this equipment suffers from detrimental performance in areas where Smart Meters are installed. Most of these consumers are not aware that they are receiving interference from all the Smart Meters within range of their equipment. In many cases, the interference, which causes random loud pops or clicks, renders the devices completely useless to the consumer. Chatham-Kent Hydro is aware that these devices will be negatively impacted, and states,
“900 MHZ telephones and baby monitors can be interfered with by the Smart Meter network. Our vendor has done testing in the area and they report that the devices ability to filter out the interference varies greatly from supplier to supplier. Some phones work perfectly fine while others report short “popping sounds” every minute or so. This interference is, although undesirable, within the realm of acceptable performance for devices operating in the 900-928 MHZ band.”
Technically, there is absolutely no way for any analog radio device to “filter out” this interference since it is co-channel interference and not a design deficiency. In other words, the undesired Smart Meter signal overpowers the desired signal on the same frequency, and there’s no filter or other technology that could eliminate it. The occurrence of interference is much more frequent than once “every minute or so” as stated. In one recent sample, over one hundred “pops” were documented in a single minute, and this kind of intensity is observed throughout much of the day and night. There were very few times where the intensity dropped to the level claimed by Hydro. The problem with Chatham-Kent Hydro’s assurance that this is “acceptable performance for devices operating in the 900-928 MHZ band” is that it is ILLEGAL to cause this interference in the first place. Industry Canada requires all equipment operating under RSS-210 to cause no interference to other users, including licence-exempt users.
Hydro Justifies Smart Meter Interference
Chatham-Kent Hydro provided the following interpretation of the rules:
The only restrictions imposed on equipment with a secondary status using this band are:
- The device cannot cause interference for primary users (primary users are licensed users of the 900-928 MHZ band of which there is only one known used for maritime radar (not a factor in our area)
- The device must accept interference from other devices
- The devices must be a low power transmitter (0-1 Watt). The TUNet modules operate at 1/2 W.
- The device must meet all Industry Canada technical specifications (as is the case for the TUNet modules).
Smart Meters operate in the 902-928 MHz frequency band, and the modules are fully certified for operation by Industry Canada and the Federal Communications Commission in the USA. i.e. the meters operate completely within regulations and are designed to coexist with any potential interferers. Because of the shareable nature of the band and the corresponding “rules” around its use, users cannot expect to have clear access, without interference from other devices.”
This interpretation is incorrect, according to Industry Canada, and could land Chatham-Kent Hydro in some expensive trouble. There is nothing about this system which is designed to “co-exist” with other users. Even though each TUNet module is Industry Canada certified, compliance with the regulations is not guaranteed. When these rules were implemented, Industry Canada and the various stakeholders which contributed input to the bandplan did not envision a mesh network of 32,000 such devices effectively monopolizing the entire band in a geographic area. The certification is for a single TUNet module, not an entire network. Further interpretation of the rules indicate that the radio receiver used by this system, which must also be certified, is to operate on a 1:1 basis; that is, one transmitter (TUNet module) must correspond with one receiver using the same 50+ channel hopset.
|RSS-210 Annex 8.1 states, “The system receivers shall have input bandwidths that match the hopping channel bandwidths of their corresponding transmitters and shall shift frequencies in synchronization with the transmitted signals.”|
The assertion that “users cannot expect to have clear access” is incorrect, as the regulations clearly state that licence-exempt users CANNOT cause interference to each other, therefore, users CAN expect to have clear access to individual frequencies in this band. Any interpretation to the contrary is a violation of the law and the gentleman’s agreement that governs shared use of this band. It appears by this statement that Chatham-Kent Hydro is knowingly causing interference and expecting everyone to roll over.
As previously stated, Industry Canada will not intervene in cases of interference, but it is still the law, enforceable in Civil Court. If an individual or business is suffering from permanent interference which renders their investment in wireless equipment useless, the law supports legal action against the offending source of interference. It is quite likely that the courts would order compensation, or could even issue an order to cease operation. Considering the many thousands of affected devices, a group of cases could be certified for Class Action.
Hydro Offers Unacceptable Solution
Chatham-Kent Hydro offered their solution to interference caused to consumer devices by Smart Meters:
“Thankfully, as time goes on, less and less devices will be operating in this band as most commercial products seem to be moving onto the 2.4GHZ and 5.8 GHZ bands.”
(Chatham-Kent Hydro also posted instructions on their website for customers to go out and purchase new equipment that used other bands.)
This is a presumptive statement, and what it really means is that they expect their system to chase consumers entirely off the band. It makes no accommodation for the thousands of 902-928 MHz devices already in use. Forcing a migration to other bands is a poor precedent, since there is nothing to stop some other user from deciding to use those bands and chasing consumer equipment to the next band, ad infinitum.
It is important to note that this could “come back” on Chatham-Kent Hydro, as their entire system could easily be chased off this band as well. It is an unprotected allocation that has been taken rather than assigned, and that is one of the dangers of using this band. Obviously, this situation exposes some weaknesses in the regulations governing the use of all these ISM bands, weaknesses being improperly exploited by Chatham-Kent Hydro. No matter how it is analyzed, Hydro has no “rights” to monopolize this band, nor do they even have any rights to use it – its use under the strictly controlled restrictions of RSS-210 just happens to be allowed at the moment.
Industry Canada Warns of Risk
When contacted, Industry Canada was not even aware of the use of 902-928 MHz by Chatham-Kent Hydro for Smart Meters, but they are now. Under the rules, IC stated that the legality of this implementation is highly questionable, but it’s worded in such a way that Industry Canada would only get involved if a licenced user is being interfered with.
However, the use of a network of 32,000 Smart Meters on this band effectively monopolizes it and prevents most other uses, which was never the intent of the bandplan, nor of RSS-210. It is highly likely that this kind of non-conforming use would be examined and banned in future bandplan updates, which could force the system to cease operation and move to a more appropriate system. Industry Canada and the Radio Advisory Board have already discussed the problem caused by Chatham-Kent Smart Meters.
Use of this band for meter telemetry required consultation with all stakeholders of the band. Nobody was consulted by Chatham-Kent Hydro, and most users are quite opposed to the ongoing implementation of these Smart Meters due to the clandestine use of 902-928 MHz without any public disclosure or consultation. Industry Canada stated that the continued use of this band by Chatham-Kent Hydro is “highly risky”, since they have no protection from interference whatsoever, and have no guarantee that long-term access to this band will continue to be allowed. They added that it doesn’t matter “who’s there first” or who spent the most money – Chatham-Kent Hydro has “no rights” when using this band; they can use it for now on a “cause no interference basis,” and will receive “no protection from interference to their system.”
Chatham-Kent Hydro erroneously seems to think that they do have exclusive access to this band, stating, “The [Smart Meter] device cannot cause interference for primary users (primary users are licensed users of the 900-928 MHZ band of which there is only one known used for maritime radar – not a factor in our area,” which is wrong.
Railway Safety Compromised
There is one licenced user locally at 911.5 MHz, and that user must not suffer any interference by law. This licence is held by the Canadian Pacific Railway as part of a data handling system to ensure railway safety. A Fixed Station is a primary user of the band and the Radiocommunication Act is very clear that it is illegal for any unlicenced or licence-exempt device to cause interference, and it could also be a violation of Transport Canada rules as well. An analysis of 911.5 MHz concludes that this frequency is indeed subject to severe interference from the Smart Meter hopset, even though the bandwidth of that channel should be excluded altogether from the hopset. If the CPR system, which runs 10 watts on that frequency as a point-to-point link, hasn’t experienced any detrimental interference to date, it is highly likely that it could once 32,000 Smart Meters are installed at 0.5 watt each. This is yet another example of the improper and short-sighted implementation of 902-928 MHz equipment.
Amateur Radio Wiped Out
The 902-928 MHz is allocated in North America to the Amateur Radio Service as a secondary user. In the absence of the primary user in this region, the Amateur Radio Service has established usage of this band, and is pretty much free to use the 902-928 MHz band to the extent permitted by the terms of their licences. Chatham-Kent Hydro states:
“The 902-928 MHz band is also designated as an amateur band, and is also classified as a secondary user … i.e. they are second priority and must not interfere with other applications. This secondary status is allowed because in many parts of Canada (i.e. in rural regions) there are no users of these bands and there is no reason why someone like the amateur radio operators shouldn’t be able to use them, as long as they don’t interfere with any primary users.”
It seems as if Chatham-Kent Hydro is claiming their use of 902-928 MHz to be considered the primary one which is protected from interference from amateurs. Likewise, the assumption that use of this band is allowed by amateurs in rural regions because no one else is using it there is unfounded.
This band is in use by licenced amateurs in all regions across North America not affected by shipborne radar, and it should be stressed that Chatham-Kent Hydro is NOT protected from any interference by Amateur Radio Operators. There has been an internationally agreed bandplan for 902-928 MHz since 1997, and this band is proving ideal for operations such as FM simplex and duplex, repeaters, high-speed data, and amateur television. There are FM, IRLP, EchoLink and digital repeaters in use on this band in Southwestern Ontario, Ohio, and Michigan, with many more planned, including several in the works for Chatham-Kent.
It is worthy to note that most of the communication potential of this band would be used for Public Safety purposes as a voluntary public service, and it is ironic that Chatham-Kent Hydro, a municipal government institution, is threatening the usefulness of this band for any purpose other than their own. Amateur use of this band is expected to grow exponentially in the near future as commercially available radio equipment begins to include these frequencies.
|Amateur Radio Overview
A few words about the secondary user of 902-928 MHz would be in order. Amateur Radio Operators, commonly known as “hams” are a special group of civic-minded people with an interest in radio communications. They must pass an Industry Canada examination to demonstrate proficiency in radio theory, regulations, operating procedures, electronics, and safety before being certified to operate. At the highest qualification, hams are allowed to operate on all amateur bands using up to 2250 watts PEP of power, and they are certified to build all of their own radio equipment including transmitters.
Amateur Radio Operators have built successful networks and systems for delivering non-commercial voice, data, images and television messages via radio signals. The networks include repeaters, satellites, internet links, shortwave communications, mobile and base radio stations. In times of trouble, Amateur Radio Operators are legendary for their ability to communicate when all other methods of communication fail. These selfless individuals and clubs volunteer their skills for the public good, by constantly training for emergency scenarios, and jumping into action on short notice when required. It is worthy to note that Amateur Radio Operators are often the FIRST or ONLY source of communication as demonstrated during hurricane Katrina, the Tsunami, Quebec ice storm, earthquakes, floods, power failures, and other emergencies. Most recently, NASA counted on amateur radio operators worldwide to provide backup communications to the International Space Station when a docking Russian vessel damaged an antenna.
Virtually every method of communication in use today relies on billions of dollars worth of private and public infrastructure, yet these networks are vulnerable to the likes of solar flares, satellite failure, weather, software glitches, natural and man-made disasters, or overgrown tree branches in Ohio. Amateurs do not rely on this infrastructure to communicate, and willingly serve as a back-up to it out of a passion for radio and dedication to public service – all for free. Amateur Radio Operators are not allowed to charge for their services as a condition of licence, which is why they are called Amateurs.
By using a spread spectrum signal across the entire band, interference with virtually any of the amateur uses of this band is guaranteed, yet the rules governing this band specifically prohibit unlicenced and licence-exempt users from causing such interference. There have already been documented cases where wireless licence-exempt business equipment was forced to cease operation for causing interference to the Amateur Radio Service. Granted, there is some ambivalence to the regulations concerning interference caused by amateurs, however, RSS-210 clearly states that unlicenced and licence-exempt users must not cause interference to other users , and that no protection is provided against interference from any user, including interference that causes undesired operation.
The consensus is that as the official secondary user, the Amateur Radio Service should not cause intentional interference to others, but cannot be prevented from causing unintentional interference to any user other than the primary ones.
Chatham-Kent Hydro seems to be saying that, “since we’re using the entire band, nobody else is allowed to cause us interference, therefore nobody else can use it and that gives us the whole band to ourselves.” There is nothing in the regulations to support this position, and it is completely contrary to the notion of “shared use.” Industry Canada policy designates 902-928 MHz as a “shared” band which is usable by licence-exempt users only on a no-interference basis in the first place, and a spread spectrum signal from 32,000 Smart Meters clearly precludes the possibility of sharing the band with anyone.
Amateur Radio Operators are generally a reasonable, public-service oriented group. However, many of their operating privileges come from years of personal effort, and the existing ham radio frequency allocations are the result of years of intense lobbying on a world-wide basis. The Smart Meter situation has gained the notice of amateurs across the country, and the RAC (Radio Amateurs of Canada) is following this case with a vested interest, as is Industry Canada, now that they are aware. It is highly likely that there will now be a coordinated effort amongst concerned users of this band to lobby for changes which prevent the type of use currently implemented by Chatham-Kent Hydro on 902-928 MHz due to the negative impact of spread spectrum on so many other users.
Official Bandplan for 902-928 MHz
The Canadian bandplan adopted in 1997 is as follows:
| 902-928 MHz
Available spectrum 26 MHz
FIXED and RADIOLOCATION PRIMARY
Amateur and Land Mobile secondary902.0 – 902.5 PACKET (<=2400 B, 25 kHz CH)
902.5 – 902.8 TTY, PACKET (<= 2400 B, < =2.5 kHz BW)
902.8 – 902.9 PACKET (<= 2.5 kHz BW), TTY, CW, EME (Earth-Moon-Earth)
902.9 – 903.1 CW; EME
903.100 NATIONAL CW/SSB DX CALLING FREQUENCY
903.1 – 903.2 CW, SSB, EME
903.200 NATIONAL SSB CALLING FREQUENCY (LOCAL)
903.2 – 903.3 SSB, SSTV, FAX, PACKET (BW < =2.5 kHz) AM, AMTOR
903.3 – 903.32 PROPAGATION BEACON NETWORK
903.32 – 903.4 GENERAL PROPAGATION BEACONS
903.4 – 903.5 SSB, SSTV, ACSSB, FAX, PACKET (BW <= 2.5 kHz) AM, AMTOR, EXPERIMENTAL (BW <= 2.5 kHz)
903.5 – 903.7 CROSSBAND LINEAR TRANSLATOR INPUTS
903.7 – 903.9 CROSSBAND LINEAR TRANSLATOR OUTPUTS
903.9 – 904.0 EXPERIMENTAL BEACONS
904.0 – 904.3 CONTROL AND AUXILIARY LINKS
904.3 – 904.5 FM SIMPLEX (25 kHz CHANNELING)
904.500 NATIONAL FM CALLING FREQUENCY
904.5 – 905.0 FM SIMPLEX (25 kHz CHANNELING)
905.0 – 907.0 HIGH RATE DATA (>=4800 B, DUPLEX)
907.0 – 910.0 FM REPEATER INPUTS (25 kHz CHANNELING)
910.0 – 916.0 FAST SCAN TV (SIMPLEX OR REPEATER OUTPUT, PAIRED WITH 922.0 928.0 AND 439.0 444.0 MHz)
916.0 – 916.5 PACKET (<= 2400 B, 25 kHz CHANNELING)
916.5 – 919.0 HIGH RATE DATA (>=4800 B , DUPLEX)
919.0 – 922.0 FM REPEATER OUTPUTS ( 25 kHz CHANNELING)
922.0 – 928.0 FAST SCAN TV SIMPLEX OR REPEATER INPUT, SPREAD SPECTRUM, EXPERIMENTAL MODES
Planned Local Uses of 902-928 MHz by Amateur Radio
There are several projects already underway in Chatham-Kent which could cause problems with the Smart Meter telemetry. A wide-area radio link is under development which will provide FM voice communications across the municipality. This will include several repeaters with remotes which are connected together, and also linked to similar systems across the world using the internet. High-speed data links are also planned that will provide wireless internet access during emergencies. Also, a television repeater is being developed for Chatham to facilitate the transmission of video between communities.
These uses will be properly licenced and coordinated. The system is designed to avoid the frequency used by the CPR, and any interference to consumer equipment could be easily tuned out by the user. It is probable that, through normal legal use, Amateur operations could unintentionally affect the Smart Meter data to the point where the entire system is unreliable.
Had the Amateur Radio Community been consulted by Hydro prior to spending millions of dollars on Smart Meters, Hydro would have been aware of pending uses of this band.
Ontario Energy Board Recommendations Ignored
The Ontario Energy Board has published “Smart Meter Implementation Plan” to assist in the province-wide adoption of Smart Meters by 2010. One of the considerations examined was the method of transferring data from individual Smart Meters to the Utility billing system. Among the systems examined were telephone, PCS, 200 MHz radio, 400 MHz radio, 1400 MHz radio, and 902-928 MHz spread spectrum. In rural areas, telephone connections were considered as the only viable option, but some forms of radio telemetry were deemed feasible in suburban and urban areas.
The OEB recognized that 902-928 MHz is allocated as a low-power licence-exempt public band, and was an option only if the population resided in a 500-700 foot radius. These guidelines recommended a propagation study to determine the level of activity from other users. It would appear that no such study ever took place in Chatham-Kent, and if it did it was deeply flawed, since it even failed to identify the existing licenced station used by the CPR, and consultations with the official secondary user of the band did not occur. In Freedom of Information requests, Chatham-Kent Hydro said the required study didn’t exist, but upon further digging it seems a study would be made available on payment of $950.
Chatham-Kent Hydro neglected to consult with the Amateur Radio community, which could have easily alerted Hydro to existing and proposed uses of the 902-928 MHz band. Further, there were no public consultations with the many citizens who own licence-exempt wireless devices operating on these frequencies. Indeed, many people may not even be aware what frequency their devices work on, or even that they use radio signals at all. The average consumer would rely on the honest disclosure by Chatham-Kent Hydro that the Smart Meter program might impact their devices in a noticeable way and render them useless.
Instead, we see evidence that the exact nature of this system has been withheld from the public, with the focus being placed instead on Press Releases hyping the award winning role of Chatham-Kent Hydro in Ontario’s Smart Meter program, and the huge cost savings realized. Ratepayers are left to wonder why their equipment no longer works properly, likely never linking the cause to the Smart Meters installed on their house and in their neighbourhood. Perhaps it’s becoming clear why the implementation cost was so much lower than OEB estimates. I also learned that it’s common for suppliers to nominate a client – the municipality – for these awards in the first place.
There was a much better option than 902-928 MHz. The OEB identified the 1400 MHz band as being feasible for suburban and urban use. Some R&D was still required on this band, but it was considered an excellent option if it didn’t run contrary to other allocations on that band. As it happens, in Chatham-Kent there are no users on this band.
Industry Canada recognizes the need for protected Automatic Meter Reading (AMR) spectrum, and recently invited comments on proposed changes to spectrum in frequencies below 1.7 GHz (DGTP-004-05). The bandplan restructuring that resulted created an allocation on this band for Smart Meter (AMR) telemetry, from 1429.5-1432 MHz. An added advantage to these frequencies is exclusive use , which is also aligned with the FCC in the United States. As a result, this North American allocation greatly enhances the availability of suitable equipment.
These frequencies require a licence, which offers long-term stability and official protection from interference. A licence provides other benefits as well, including the use of higher transmitting power and more efficient modulation techniques, like packet (since data would not have to be transmitted several times redundantly to account for interference and co-channel occupancy). This encourages the responsible and efficient use of valuable radio spectrum, instead of the wasteful method currently employed . Higher power radio signals could overcome local propagation difficulties, and eliminate the need for many of the 220 MHz data repeaters which would be needed with the 902-928 MHz system. RSS-142 details the specifications of the standards. This is an area where Chatham-Kent Hydro could have really proven itself a leader in the industry, but failed.
Chatham-Kent Hydro Supported the Loss of 220-222 MHz Band to Amateurs
Some interesting observations can be made referring to Industry Canada’s Gazatte Notice No. DGTP-004-05 – Proposals and Changes to the Spectrum in Certain Bands Below 1.7 GHz . In a letter to Industry Canada dated January 20, 2006, Chatham-Kent Hydro stated the need for frequency spectrum allocated to automatic meter reading and power outage notification. They applauded the initiative to allocate the 220-222 MHz band for this purpose and voiced strong support, citing its suitability for their communication solutions. No mention was made of 902-928 MHz which was already being implemented by Chatham-Kent Hydro at the time (unbeknownst to Industry Canada), nor of 1400 MHz which was being allocated specifically for this purpose. As a direct result of interventions like this, the frequency range of 220-222 MHz was lost from the Amateur Radio Service. Identical letters from the Ottawa River Power Corporation and Waterloo North Hydro Inc. suggest a bit of form-letter lobbying going on. Hydro seems intent to support the removal of as much spectrum from the Amateur Radio Service as they can get away with.
The discussion in Section 8.2 of DGTP-004-05 should have been of greater interest since it specifically refers to AMR allocations and the new sub-band created from 1429.5-1432 MHz to permit primary protected use of AMR. In reality, the Ontario Energy Board identified the 220-222 MHz band as being mostly unsuitable for AMR purposes. The discussions in DGTP-004-05 suggest that the licence-exempt 902-928 MHz band might accommodate AMR using an expected 1 MHz bandwidth, but most effort went towards creating a sub-band solely for utility AMR.
The 220-222 MHz band is claimed to be in use by Chatham-Kent Hydro to transmit all the data collected from the 902-928 MHz spread spectrum sources back to the central office billing computers. It is pertinent that all the data from the 26 MHz bandwidth used by the meters can be easily compressed into the 2 licenced frequencies in the 220-222 MHz band [220.9725 and 221.9725 MHz] with only 3.2 kHz bandwidth (0.0032 MHz), effectively proving the wasteful and inefficient use of the 902-928 MHz band.
|Updates in 2010
When Chatham-Kent Hydro ignored the writer’s concerns, the media was contacted and given a full overview of the problem. The phone lines at Chatham-Kent Hydro were immediately overloaded by people with interference complaints, now that they knew the source. Embarrassed hydro officials were summoned before Chatham-Kent council, where they gave a glowing report that was seriously misleading, and promised to help customers experiencing interference.
In private, Chatham-Kent hydro told the writer that they had seriously underestimated the interference the meters would cause, but this is not what council was told. They admitted nobody on staff had any experience with radio systems, and could not notch out the interference. Hydro then proceeded to issue press releases promoting their Smart Meter progress, including photo ops with the mayor, and winning an industry award.
In response to the interference complaints, Chatham-Kent Hydro was forced to a page on their website that said in part:
In other words, Hydro wasn’t too happy being exposed in the media. That web page has disappeared, while 900 MHz devices are still being sold, and customers still can’t use them.
In retaliation for those “newspaper articles” and council grilling, Chatham-Kent Hydro arbitrarily demanded that the writer pay a deposit under threat of disconnection, to the maximum amount their policy allowed. Several months later, they demanded another deposit, and were able to cite new rules allowing them to force the payment of a higher amount.
It gets better. When the president of Chatham-Kent Hydro retired, he had himself appointed to the committee that administered the writer’s employment. Within days, I experienced sabotage and interference with my employment.
The mayor of Chatham-Kent sits on the Chatham-Kent Hydro board. His office was also involved in a smear campaign against the writer which involved private municipal information showing up in the wild to damage my reputation and credibility in the community. Chatham-Kent Hydro was really not happy about this research. Plenty was done to retaliate, but not one single point was challenged. Authorities are currently investigating the unauthorized release of my private hydro account information that included defamatory comments about my family.
While Chatham-Kent Hydro officials were deposing to council about how inexpensive their smart meter implementation had been, they were preparing OEB applications to hike the smart meter cost recovery by 200%.
Security of Mesh Network
Most Smart Meter companies promote the security of their system. This feature is conspicuously absent from the TuNet technical specifications. While there may be some form of encryption, perhaps they used a cheap off-the-shelf chipset and relied on security by obscurity. Tantulus states their Smart Meters will interface easily with other smart devices using a data format that’s compatible with other manufacturers’ products.
It’s likely only a matter of time before somebody is able to hack into the system and monitor or alter traffic. There are plenty of nefarious reasons why people might want access to billing data.
In conclusion, many factors as listed below have demonstrated why the Chatham-Kent Hydro Smart Meter implementation is seriously flawed. For only 3 cents per customer per year, Chatham-Kent Hydro could have used licenced and protected Smart Meters that eliminated all of these problems.
Chatham-Kent Hydro defied Ontario Energy Board guidelines requiring a propagation study and consultation with local users of 902-928 MHz
Unlicenced and licence-exempt users are strictly prohibited from causing interference to any other users, including other unlicenced users
Hydro has no rights to use the 902-928 MHz band beyond the temporary ability to use the band on a non-interfering licence-exempt basis
Hydro’s use of this band prevents clear access to the band for every other user
Industry Canada does not sanction the wasteful use of the entire 902-928 MHz band for this purpose, and warns of the serious financial risk of investing in unlicenced systems
Interference is caused to a licenced user, a Canadian Pacific Railway safety system
Amateur Radio is denied the legitimate use of the entire band by telemetry interference
Communication systems are being installed locally that could cause the Smart Meter telemetry to fail
Other users could be licenced to use this band by Industry Canada without regard to existing unlicenced use by Hydro
In the United States, the Amateur Radio Service is the Primary user; the same status is being sought in Canada
Residents and businesses are prevented from the peaceful enjoyment of their wireless electronic devices
Hydro’s attitude that existing users will just “move off” the band while claiming protection from interference to Smart Meter telemetry is high-handed and unsupported by the regulations
Hydro has no enforceable protection against any form of interference, even if it causes the entire system to fail
Smart Meter telemetry has no legal status on this band and could be forced by IC to cease operation at any time
Using a 26 MHz wide bandwidth to transmit data that can be accommodated in a 1 MHz bandwidth is wasteful and irresponsible pollution of the electromagnetic spectrum which violates the responsibility use the minimum bandwidth required to maintain communications
Spending $4.6 million of ratepayer funds to build a telemetry system with no legal status nor long-term viability while serving it as a model for other utility companies to emulate could be considered a serious miscalculation and foolish
The system may not be all that secure. An open mesh network designed for easy cross-platform data integration could be subject to attack.
When time-of-use billing kicks in, every Chatham-Kent Hydro bill will increase, even if people do all their living at night. Our bills are now substantially higher, despite conserving religiously and contrary to assurances by Hydro officials when the plan was rolled out. Windsor and Essex have currently deferred time-of-use billing due to the negative impact.
The present use of Smart Meters on the 902-928 MHz band is unsanctioned by Industry Canada, which has already warned that there is no long-term life to this system. It should have been stopped right away and switched to a licenced system with predictable long-term viability before further ratepayer money was wasted. One user simply cannot wantonly monopolize the entire band without regard for other legitimate users.
It is unfortunate that a substantial amount of ratepayer money has been spent on this project already.
Report prepared by:
Industry Canada (IC)
Ontario Energy Board (OEB)
Radio Amateurs of Canada (RAC)
American Radio Relay League (ARRL)
Chatham-Kent Amateur Radio Club
Municipality of Chatham-Kent
Radio Advisory Board of Canada