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RE: NBP RFI Reply Comments: Communications Requirements

The National Rural Electric Cooperative Association and American Public Power Association file these brief reply comments in support of the comments and reply comments filed by the Utilities Telecom Council (“UTC”). Both organizations strongly believe that the Administration should ensure that adequate spectrum is available for internal, utility networks. Integrating Smart Grid technologies into Cooperative and Public Power Systems will necessitate enhanced communications networks. In some instances, Cooperatives and Public Power Systems may choose a commercial provider for at least some portion of their communication network service needs. However, continued concerns about coverage gaps, reliability, survivability and cost will likely mean that most Cooperatives and Public Power Systems will continue to rely on their own, private communications networks to support mission-critical functions.