Joint Comments By Consumer Advocates on NERC Cybersecurity to FERC

Public Citizen pushes for governance reforms at America's electricity reliability regulator

By Tyson Slocum

Public Citizen and the National Association of State Utility Consumer Advocates offer comments on June 19, 2020 to the Federal Energy Regulatory Commission in response to the North American Electric Reliability Corp. Compliance Filing submitted June 1, 2020. Our comments provide three suggested reforms to enhance representation for household consumers and strengthen NERC governance. Our three suggested reforms are:

• NERC should reform its charter to require that at least one of the two voting seats of the small end-use electricity sector be reserved for a bona-fide consumer advocate.
• One of 10 at-large seats be reserved for an organization that demonstrates bona-fide representation of household consumers.
• FERC should require NERC Board membership that is independent of utility interests or other conflicts and should include allocating at least one Board seat to someone with significant experience representing household consumers in regulatory proceedings.

NERC_RSTC-Joint Comment-Public CitizenandNASUCA