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As Verizon noted in its opening comments in response to the Department of Energy’s Request for Information (RFI), effective communications networks and services are critical to the success of Smart Grid technology. Existing commercial broadband networks built and operated by experienced communications providers would best facilitate the implementation of Smart Grid technology, which requires the highly secure transmission and processing of vast amounts of information to and from consumers and electricity producers and distributors. As evidenced by comments submitted in this proceeding, established communications providers not only are capable of meeting the communications needs of the utility sector as Smart Grid technology is implemented – they are already doing so.

The Edison Electric Institute ("EEI"), on behalf of its member companies, hereby submits the following reply comments in response to the Request for Information ("RFI") by the Department of Energy ("Department" or "DOE") regarding the current and future communications requirements of utilities, including, but not limited to, the requirements of the Smart Grid, in an effort to implement certain recommendations of the National Broadband Plan

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.

Attachment to NBP RFI: Communications Requirements- Reply Comments of AT&T Inc.

AT&T Inc., on behalf of itself and its affiliates (“AT&T”), respectfully submits these reply comments in response to the Department Of Energy‟s Request for Information (“RFI”) on the communications requirements of electric utilities in Smart Grid deployments.1 In its initial comments, AT&T highlighted the expanding demand for network connectivity and how utilities can benefit from leveraging new network technologies deployed by commercial communications operators to optimize the performance, scalability, security, reliability and cost effectiveness of their Smart Grid applications deployments. Commercial communications providers possess the technological and human resources to help utilities meet these complex and critical needs. Moreover, by employing commercial service for many of the Smart Grid applications, utilities can concentrate on assuring the reliable delivery of electricity to consumers, optimizing energy utilization within the existing electrical grid, and implementing new information technologies that will allow utilities to enhance billing, customer relationships, demand response and energy management systems. At the same time, the utilities will be reducing their exposure to technological obsolescence in an environment of rapidly changing technology and yet-to-be- defined applications requirements. AT&T recommended that policy makers, including the DOE, encourage the serious consideration of commercial services for Smart Grid applications.

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.

The Edison Electric Institute ("EEI"), on behalf of its member companies, hereby submits the following reply comments in response to the request by the Department of Energy ("DOE" or "Department") for information on state efforts to enact Smart Grid privacy and data collection policies; utility practices and policies regarding data access and collection; third party access to detailed energy information; the role of the consumer in balancing benefits of data access and privacy; and policies and practices that should guide policymakers in determining who can access consumer energy information and under what conditions.

Southern Company Services, Inc. ("Southern"), on behalf of itself and its operating affiliates, hereby submits its reply comments in response to the Department of Energy's ("DOE's") Request for Information ("RFI"), released May 5, 2010, about current and projected communications requirements of electric utilities.1 Southern appreciates the opportunity to provide DOE with additional information and to respond to the initial comments submitted in this proceeding. As discussed more fully below, Southern believes that privately-owned and operated systems will continue to be needed for command and control operations. In addition, Southern is not opposed to using some commercial services for non-mission critical applications as long as reliability, cost, engineering, and other functionality issues are adequately addressed.

Booz Allen Hamilton (Booz Allen) has had an enduring relationship with the Department of Energy (DOE) for more than two decades. We are pleased to be responding to the DOE’s Request for Information (RFI), Implementing the National Broadband Plan by Studying the Communcations Requirements of Electric Utilities to Inform Federal Smart Grid Policy, with our perspectives on the use of broadband communications technology to meet emerging Smart Grid requirements. In its RFI, the DOE acknowledges the multiple interdependencies, diverse topics, and challenges in addressing the nine questions posed on Smart Grid and utility industry communications network requirements. Booz Allen is aware of the central role that well-defined and executed industry communications networks requirements management can play in supporting and sustaining successful industry transformative mandates such as that facing the utility industry in Smart Grid. Since we are certain that the DOE will receive no shortage of quality inputs to its specific inquiry areas from a diverse set of industry stakeholders, we wanted to offer a response which provides an independent perspective structured around critical issues and a framework of supporting observations. We have attempted to evaluate these issues with an eye to the DOE’s role with respect to the National Broadband Plan and its role as a catalyst in advancing Smart Grid technology. As such, our response does not directly answer each of the individual RFI questions, but instead offers recommendations which the DOE may wish to consider to ensure success in its Smart Grid communications network requirement work streams including recommendations for risk mitigation.

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 bel...