Comment on Smart Grid Submitted to California Public Utilities Commission on Privacy

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Samuelson Clinic submitted comments to the California Public Utilities Commission on Privacy and the “smart grid” on behalf of the Center for Democracy & Technology.

The Samuelson Clinic, on behalf of its client the Center for Democracy & Technology, submitted formal comments in conjunction with the Electronic Frontier Foundation to the California Public Utility Commissions’ Smart Grid Rulemaking. The comments urge the Commission to build strong privacy protections into the Smart Grid and to issue privacy protecting regulations based upon the Fair Information Practice principles. The new smart meters being installed in homes around California and the country provide much more data on energy customers than ever before-up to 750 to 3000 data points per month per household. Energy usage information of this granularity can reveal not only the various appliances that are consuming power within the household, but also their current operations. This radical departure from the traditional once-a-month manual readings can reveal specific household activities such as sleep, work, and travel habits and allows utilities and third parties with access to the information to “see” what is going on inside the home. Samuelson Clinic students Jonas Herrell, David Marty, Longhao Wang and Shane Witnov worked with supervisors Jennifer Lynch and Jennifer Urban to draft the comments.

Administrative and Regulatory Filings