These comments are submitted on behalf of the National Association of State Utility Consumer Advocates (NASUCA) in response to the request for information (RFI) of the Department of Energy (DOE) entitled “Implementing the National Broadband Plan by Studying the Communications Requirements of Electric Utilities to Inform Federal Smart Grid Policy.” See 75 Fed. Reg. 26206 (May 11, 2010).1 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.