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March 7, 2011

Dr. Patrick Gallagher

Under Secretary of Commerce for Standards and Technology

Director, National Institute of Standards and Technology

Co-Chair, National Science and Technology Council’s Sub-Committee on Technology

100 Bureau Drive, Stop 1000

Gaithersburg, Maryland 20899-1000

SOS_RFI@nist.gov

RE: Docket No. 0909100442-0563-02 (RFI)

Docket No. 0909100442-1012-03 (RFI extension for comment)

“Effectiveness of Federal Agency Participation in Standardization in Select 

Technology Sectors for National Science and Technology Council’s 

Sub-Committee on Standardization”

Background

As one of the world’s leading suppliers of power generation and energy delivery 

technologies, GE Energy welcomes the opportunity to provide feedback about Federal 

Agency participation in standards setting for the smart grid. The smart grid is essential to 

addressing the energy demand, security and environmental challenges we face. System 

architecture and technical standards are crucial to the transformation of our grid into a 

more automated, interactive and intuitive power delivery system. They are the foundation 

for bringing together the electrical and communications infrastructure and for evolving 

technology to meet many and disparate needs. System architecture and technical 

standards that foster interoperability provide a framework for development, a roadmap for 

progress and a catalyst for continued industry investment. GE Energy strongly believes 

that technical standards can accelerate innovation and investment in emerging 

technologies, provided those standards are developed and adopted in an open, 

consensus-based fashion.

GE Energy

Digital Energy 

John D. McDonald

Director, Technical Strategy & Policy Development

20 Technology Parkway, Suite 380

Norcross, GA 30092

USA

T 770.662.7081

F 770.447.7200

johnd.mcdonald@ge.com 
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GE Energy recognizes that the Federal Government has a long history of working alongside 

the private sector in developing and adopting technical standards. In 1995, federal policies 

were promulgated in the Office of Management and Budget (OMB) Circular A-119 to 

provide guidance for Agency participation in voluntary consensus standards bodies. 

According to these policies, Agency representatives should participate on an equal basis 

with other members. Moreover, the explicit purpose of Agency participation should be to 

eliminate the need for government-unique standards and further national goals and 

objectives.

More recently, the creation of a Smart Grid Interoperability Panel (SGIP) signals a renewed 

commitment by the Federal Government to engage the private sector in development and 

adoption of technical standards. Established in response to the Energy Independence and 

Security Act (EISA) of 2007, which assigned the National Institute of Standards and 

Technology (NIST) responsibility for coordinating development of smart grid interoperability 

standards, the SGIP provides an open forum for stakeholder participation in the NIST 

process. GE Energy is proud to be a part of the SGIP, and I personally am excited about 

moving into my second year of chairing the SGIP Governing Board. The testimony I 

provided on July 1, 2010, to the House Committee on Science and Technology, SubCommittee on Technology and Innovation assessed coordination and progress made on 

smart grid system architecture and technical standards. This work continues in earnest 

today.

Guiding Principles

In June 2010, GE Energy shared the following principles with the American National 

Standards Institute (ANSI) with respect to the creation of a National Science and 

Technology Council (NSTC) Sub-Committee on Standardization. These principles still offer 

the guidance necessary for Federal Agency participation in private-sector standards 

setting: 

1. Encourage consensus-based adoption of technical standards

2. Balance federal leadership with private-sector innovation

3. Promote development of international standards

4. Utilize federal R&D to support standards development

5. Educate stakeholders to accelerate deployment of standards

1. Encourage consensus-based adoption of technical standards. While the Federal 

Government can – and should – participate in the development of technical standards, the 

Government should make every effort to avoid choosing “winners” among competing 

technologies. Rather, federal agencies should encourage the consensus-based adoption of 

technical standards by working alongside the various stakeholders in standards 

development organizations (SDOs), recognizing that a consensus-based approach 

promotes competition as the primary means for determining a “winner” among competing 

technologies. The prospect of competition, in turn, can inspire investment and innovation 

within the market. On the other hand, a consensus-based approach deliberately avoids 
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the perception of government intervention in competitive markets. GE is concerned that any 

government effort – real or perceived – to select technical standards might be construed as 

a measure to protect domestic manufacturers from international competition, and could 

therefore inspire other governments to respond in kind by adopting standards that favor 

national champions.

2. Balance federal leadership with private-sector innovation. The Federal Government 

should complement the efforts of consensus standards bodies by providing leadership in 

the debate over open versus proprietary standards. Open technical standards are essential 

to achieving national priorities, including the build-out of the smart grid, as they encourage 

investment among both vendors and customers. For example open standards can support 

vendors’ efforts to develop new and innovative functionalities for existing smart grid 

platforms, and can reduce the likelihood of “vendor lock-in” among utilities that are just 

now laying the groundwork for the smart grid. To encourage the adoption of open 

standards for the smart grid, the Federal Government should identify those critical points 

along the electric grid – such as the utility-customer interface – where open standards are 

required. However, the Government should not go so far as to mandate or endorse a 

particular open standard; rather, that decision should remain with the appropriate 

consensus standards bodies. For other points along the grid, the government should 

encourage consensus standards bodies to determine the best technology from all 

competing options.

3. Promote development of international standards. The Federal Government should also 

encourage collaboration among international and regional SDOs as a means to promote 

global competition within markets for smart grid and other emerging technologies. To this 

end, the Government can play the role of advocate or facilitator. In instances where North 

American SDOs have settled on an open standard for a particular smart grid function or 

technology, the Federal Government can advocate for that standard to be adopted by 

other international or regional SDOs. Adoption might entail wholesale endorsement of that 

standard by an SDO, or it might involve the integration of that standard into existing – and 

potentially competing – standards already endorsed by other SDOs. Similarly, the 

Government should actively seek out instances where competing regional standards 

threaten to fragment the smart grid market. In such cases, the Federal Government can 

work through existing government and business channels to engage relevant stakeholders 

on the adoption of one common standard. The end result is the promotion of international 

standards in lieu of regional standards, which supports broad market access and 

competition among smart grid vendors.

4. Utilize federal R&D to support standards development. The Federal Government can 

further strengthen the public/private partnership on technical standards by awarding 

research grants that support the development, adoption, and certification of standards for 

critical technologies. With respect to the smart grid, these grants might target those critical 

points along the grid where open standards are required (see paragraph 2), or at the very 

least they should target the priority areas designated in the NIST Framework and Roadmap 

for Smart Grid Interoperability Standards. To make the grants as effective and impactful as 

possible, the Government should encourage collaboration between academia and the 
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private sector to fully leverage our nation’s resources. In addition, the Government should 

require that grant awardees be co-sponsored by an international SDO, or otherwise have 

a formal channel for engaging one or more international SDOs for the purpose of sharing 

the research findings. Such engagement with international SDOs can advance the Federal 

Government’s efforts to promote common international standards.

5. Educate stakeholders to accelerate deployment of standards. The Federal Government 

can accelerate deployment of technical standards by educating stakeholders on the 

applications and benefits of newly adopted standards. As new technical standards are 

introduced, several factors can impede customer investment; these include: lack of 

awareness, fear of the unknown, uncertainty around benefits, and concerns over 

interoperability and conformance testing procedures. For example, in May 2009, NIST 

published an initial list of 16 technical standards to help ensure interoperability among 

smart grid components. Yet the adoption rate among utilities has been slower than 

anticipated, due in large part to the concerns just listed. The Federal

Government can help overcome this reluctance by launching a campaign to educate 

utilities, vendors, and regulators on the merits and applications of NIST-endorsed smart 

grid standards. More broadly, the Government should include stakeholder education as a 

critical element of its engagement strategy with consensus standards bodies, particularly in 

cases where standards are being developed for critical national needs.

Other Considerations

In addition to the guiding principles, GE Energy would like to specifically highlight the 

following areas for improving the overall effectiveness of Federal Agency participation in 

standards setting for the smart grid.

 NIST should continue to play a coordinating and facilitating role, rather than a 

leading role, with actual NIST participants skilled in both process and technology

 NIST’s outsourcing of administration and project management should be to neutral 

companies which are not heavily invested in the smart grid

 The NIST work process should be as inclusive and transparent as possible, 

welcoming a variety of stakeholders and even encouraging international 

cooperation and collaboration 

 The NIST Roadmap – which establishes standards, priorities and a framework to 

achieve smart grid interoperability – should allow for intellectual property issues to 

be addressed and managed as they traditionally have been through the SDOs

 The nature of the respective directives and relationship between NIST and the 

Federal Energy Regulatory Commission (FERC) needs further clarification
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GE Energy also suggests that comments filed in response to FERC’s Supplemental Notice 

dated February 16, 2011, Docket No. RM11-2-000, will provide tremendous insight into the 

private sector’s ongoing assessment of coordination and progress made on smart grid 

system architecture and technical standards.

Respectfully submitted,

John D. McDonald

Director, Technical Strategy & Policy Development

Digital Energy

GE Energy