In comments submitted to the Federal Energy Regulatory Commission (FERC) on the Commission’s draft Smart Grid Policy Statement, the National Rural Electric Cooperative Association (NRECA) voiced concern that the draft policy presumes all investments labeled as “Smart Grid” would be “used and useful” and does not require regulated entities to provide evidence to demonstrate that the investments are prudent:

As important as it is for the industry to take advantage of reasonable opportunities to adopt those technological advances that help utilities provide better service or lower the cost of power to consumers, not all investments in advanced technology will be “smart.” The Smart Grid should not be viewed as an end in itself, nor should consumers be required to accept nebulous promises of future benefits. Consumers should not be required to pay for investments in the Smart Grid if they do not get clear benefits from that investment.

NRECA also urged FERC and other stakeholders to be patient as the industry develops consensus on interoperability standards for smart grid technologies.

Given the early state of the industry’s understanding of “Smart Grid” it will take time for the industry to reach a good understanding of the use cases for which an interoperability standard must work. While the lack of a standard does slow the maturation of the Smart Grid, a bad standard – developed with insufficient understanding of the manner in which the Smart Grid might be implemented – will do more long-term harm. Patience, although difficult, is critical.

NRECA’s comments reaffirmed its support for a two-step process outlined by Congress in the Energy Independence and Security Act, in which the National Institute of Standards and Technology develops standards in coordination with state agencies and stakeholders that are subsequently adopted by FERC.