McMillan, Acquanette (Netta)
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3-- Yadi
Monday, May 19, 2025 2:41 PM
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Public Comment - Pasadena City Council Meeting 05/19/2025 Public Comment - Pasadena City Council - 05-19-25 AMI.pdf [ I ] CAUTION: This email was delivered from the Internet. Do not click links or open attachments unless you know the content is safe. Report phish using the Phish Alert Button. For more information about the Phish Alert Button view article "KB0011474" on the DolT portal.
Hi,
Please find attached my public comment for the May 1 9, 2025 Pasadena City Council Meeting, agenda item 1. Advanced Meter Infrastructure (AMI) Project Management Services.
Thanks,
Yadi
(Attachments: 1)
1 05/19/2025
Item 1
1. Advanced Meter Infrastructure ("AMI") Project Management Services AMI System Security - Department of Energy1
STAKEHOLDER SECURITY CONCERN
Residential Customer | Privacy
Integrity of information and system control
Integrity of system and compliance with regulations
Utility Operator
Regulators
Compliance with contractual obligations and regulationsTelecom Provider Table 10 - Stakeholder Security Concerns
Privacy and Cybersecurity
The staff reports rates that "a multi-department selection team of 11 City staff members completed the [AMI RFP] evaluation"
1. Did the City staff team evaluate AMI cybersecurity and privacy concerns?
2. In what ways is the City addressing cybersecurity and privacy issues with AMI use?
3. Will the City obtain consumer consent to share data with third parties? Will consumers have the option to opt out of the sharing of their data?
4. What are the costs and life expectancy of the meters and related communication equipment and software, the reliability/resilience benefits, and justification of the benefits and costs?
5. Are there data governance plans or appropriate changes to data architecture and a comprehensive master data management agreement that address concerns? According to research and historical data, "AMI'S data storage and communication method make the AMI system more vulnerable to different threats and cyber-physical attacks."2 The ACEEE (American Council for an Energy-Efficient Economy) states the need to "ensure that the investment has adequate cybersecurity protections, that customer privacy is protected, and that utility costs may be substantial while customer benefits may not be equitable across a customer class."3
It is high time the City implements a comprehensive privacy program...for our safety and security.
Yadi
Pasadena City Council
May 19,2025
1. Advanced Meter Infrastructure (AMI) Project Management Services 1httDs://www.enerav.aov/sites/Drod/fites/oeDrod/DocumentsandMedia/14-AMI System Security Requirements updated.D df
2httDS://link.SDrinaer.com/content/Ddf/10.1186/s44147-024-00422-w.Ddf 3 httDS://Dubs.naruc.ora/Dub/4DE49EE6-1866-DAAC-99FB-B36D6E27919D