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NBP RFI: Communications Requirements - Reply Comments of Utilities Telecom Council

The Utilities Telecom Council hereby files its reply comments in response to the Department of Energy (DOE) request for information on the communications needs of electric utilities and other such critical infrastructure industries (CII). The comments on the record- including those by APPA, EEI and NRECA, as well as API – strongly support utility access to licensed spectrum in order to support smart grid and other CII communications needs. Utilities and other CII agree that they lack access to suitable spectrum to support smart grid and other communications needs. They also agree that while they may use commercial services for some communications needs, private internal networks are essential for mission-critical communications which affect grid reliability or worker or public safety. By contrast, only a few comments oppose utility access to spectrum, and they raise general policy arguments in support of the use of commercial networks to the exclusion of private networks. The record as a whole reflects that the communications needs of utilities are not so cut and dry; and therefore policymakers should not force utilities to make a choice between commercial and private networks. Instead, utilities should be provided the options they need to meet their communications needs, and providing access to spectrum is an essential component to meet the communications needs of utilities and other critical infrastructure industries.