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Comments by the National Association of State Utility Consumer Advocates

The National Association of State Utility Consumer Advocates (“NASUCA”) hereby submits the following comments in response to the United States Department of Energy (“DOE”) Request for Information (“RFI”) entitled “Implementing the National Broadband Plan by Empowering Consumers and the Smart Grid: Data Access, Third Party Use, and Privacy.” See 75 Fed. Reg. 26203 (May 11, 2010). The RFI requests comments and information from interested parties to assist DOE in understanding current and potential practices and policies for the states and other entities to empower consumers, and perhaps others, through access to detailed energy information in electronic form—including real-time information from smart meters, historical consumption data, and pricing and billing information.
NASUCA is a voluntary organization comprised of offices from 40 states and the District of Columbia, charged by their respective state laws to represent utility consumers before federal and state utility regulatory commissions, before other federal and state agencies, and before federal and state courts. Many NASUCA members have extensive experience with regulatory policies governing the utility industry and have participated in proceedings concerning smart grid and consumer privacy issues. NASUCA members’ primary interest is the protection of residential and other small utility consumers’ interests.