Schneider Electric 

1601 Mercer Road 

Lexington, KY 40511 

Tel. (859) 243-8000 Fax (859) 245-7970 

www.us.schneider-electric.com 

March 7, 2011

Comments to Federal Register Notice:  

Docket No. 0909100442‐0563‐02

“Effectiveness of Federal Agency Participation in Standardization in Select Technology Sectors

for National Science and Technology Council's Sub‐Committee on Standardization”

Via email: SOS_RFI@nist.gov

Schneider Electric appreciates the opportunity to respond to the subject NIST Request for

Information.   

Executive Summary of our Comments

The private sector standards system of the US has been a model of success for decades.  It has

produced a level of standardization that has provided benefits in both job creation and societal

improvements.    The involvement of the federal government in the private sector system is

critical to the continued success of the system.    The government can provide expertise and

leadership in the US standards system and by doing both can often satisfy public policy needs

and regulatory objectives through the effective development and implementation of standards.

A summary of elements that we believe deserve further attention and consideration can be

outlined as follows:

• Expand the role of NIST as overall coordinator of the federal government’s participation and

leadership in the private sector system.

• Improve the communication of national priorities and governmental needs to the private sector

players.  ANSI (American National Standards Institute) can help bridge this communication gap

in a positive manner.

• As the private sector, we have to be more responsive and receptive to the needs of the federal

government and ensure that any private sector solution developed through the standards

system can truly address the communicated need.   

• Expand the role and authority of the Standards Executive within the federal agencies so that

they can truly be the central coordinating point for both standards policy and technical positions

of the agency.   
Schneider Electric 

1601 Mercer Road 

Lexington, KY 40511 

Tel. (859) 243-8000 Fax (859) 245-7970 

www.us.schneider-electric.com 

• Expand the role of the Interagency Committee on Standards Policy (ICSP) such that both the

agency leadership and policy makers understand its role and recognize the committee as an

appropriate place for development of positions of the federal government in standards related

issues.

• Provide agency leadership with a better understanding of the importance of standards and the

role they can play in helping accomplish both public policy and regulatory needs.

• Look for better ways to integrate standards into the regulatory process so that updates to the

standards can be better implemented without extensive rulemaking.

Who We Are

As a global specialist in energy management with operations in more than 100 countries,

Schneider Electric offers integrated solutions across multiple market segments, including

leadership positions in energy and infrastructure, industrial processes, building automation, and

data centers/networks, as well as a broad presence in residential applications. Focused on

making energy safe, reliable, and efficient, the company's 110,000+ employees achieved

worldwide sales of more than $26 billion in 2010, through an active commitment to help

individuals and organizations “Make the most of their energy”.

We participate extensively in the US standards system at both the policy and technical levels

and look forward to an expanded level of participation from the federal government.  

The pages that follow provide additional detail on our views on specific elements of the RFI.  

Should you desire to have further discussions regarding our comments or would like our views

on additional questions, please feel free to contact me at any time.

Sincerely,

Jim Pauley

Vice President, Industry and Government Relations

Schneider Electric

Email: jim.pauley@schneider‐electric.com

Phone: 859‐245‐7923
Comments from Schneider Electric to NIST RFI Page 3 of 5

Schneider Electric Comments to the NIST RFI

For the specific technology sectors outlined in the RFI, we will focus briefly on the efforts in

Smart Grid and then offer some overall comments on the effectiveness of Federal participation

in standards development and the importance of that participation.

Smart Grid

Smart Grid is a critical area for not only Schneider Electric but also for the future energy security

of the United States.  The NIST program for Smart Grid created a structure for working with the

private sector that better engaged various interests in a common direction.  More importantly,

it created a national imperative that better defined the overall goals that reached across

various industry sectors and it is placing pressure on the private sector to produce outputs to

accomplish those goals.    This serves as an excellent example of the role that the Federal

Government should be playing in standards policy.  

The challenge is now to deliver on standards that can support the direction offered by the SGIP

process and utilize those standards in both the regulatory and private sector applications.    

We encourage the Subcommittee on Standards (SOS) to utilize the overall framework offered

by Smart Grid to advance other national priorities into the private sector standards system.  To

be successful, the Federal Government has to clearly articulate that the outcomes of these

frameworks will be the basis on which any potential regulation or requirements are based.  This

is a very key factor in motivating the private sector to participate actively in the framework.

Using the Private Sector Processes to Accomplish Public Policy Objectives

Government agencies and regulators have to do a better job at clearly articulating the overall

goals they are attempting to achieve and what role standards are expected to play in achieving

that goal.    Too often, we rush to talk about specific technical details without a good

understanding of the intended purpose.   

In addition, the private sector has to work to better understand government needs and respond

to those needs.  The model can work, but both sides have to ensure they are pushing in the

same direction.   

An excellent example that is in need of this expanded dialogue and coordination is the area of

Electric Vehicles.    There are numerous standards activities underway without a central

coordinating point to ensure that the activities are aligned toward a common purpose.    In

addition, the Federal Government has not clearly expressed what it envisions as necessary parts

of the roadmap to accomplish the public policy objectives in the EV arena.

Recently, ANSI held an initial coordination meeting of a possible steering committee for a

Standards Panel on Electric Vehicles.  A body of this type under the ANSI umbrella can provide

the needed national coordination in the standards arena provided there is strong support from

the federal government.  This effort can become the ideal place where the federal government
Comments from Schneider Electric to NIST RFI Page 4 of 5

can articulate its objectives for electric vehicles and the private sector can help respond to

those objectives in a positive manner.

Federal Government Participation in Standards

The Federal Government is a stakeholder in many standards activities.  That stakeholder role

can be from multiple perspectives ‐ public policy, regulatory or procurement.  Because of these

roles, there is as much need for the governmental input into the development of the standard

as there is input from industry or other stakeholders.  Today, there are agencies that do this

participation very well and others where they are nonexistent in the process.  We believe that

improvements in participation can be achieved as follows:

Interagency Committee on Standards Policy (ICSP)

The ICSP role needs to be strengthened and expanded.    Not every agency is actively

participating and the role of the ICSP is often relegated to lower level issues.  There is a strong

opportunity to better utilize the ICSP as a focal point for coordination across the agencies and

should work to create a unified federal government position on standards policy wherever

possible.  This will require a commitment to the ICSP from those at the highest levels within the

agencies and will require adequate resources to participate in the development of those

positions.

Standards Executives

The role of the Standards Executive within the agencies needs to be redefined and expanded.  

This person should be the focal point for any particular agency on standards issues.  Today, they

often lack the authority to represent the overall agency and in many cases lack the support of

the agency itself.  Through a reinvigorated and expanded role, this position would become the

focal point for a unified position on a particular issue of importance to the agency.    The

executive could also focus on future standards issues as well as provide definitive guidance to

other agencies as part of the overall federal government effort.    Every agency that has an

interest in standards should have a Standards Executive in place with the full support of the

highest levels of the agency.  One of the key objectives would be to make sure that the agency

speaks with a single voice and does not give conflicting messages from different parts of the

agency to the external standards community.

Consistent Approach to the ability to Participate

There are still very broad interpretations among the different federal agencies about “how”

they are permitted to participate in standards setting activities.    Some have interpreted that

they cannot participate at all, others have said they can only play a nonvoting “advisory” role

and others participate fully as voting members.  Although we recognize that there may be some

limitations imposed by laws that set up an agency, there needs to be a more consistent

approach among those agencies that have placed limitations on their own participation

because of misunderstanding or misinterpretation.    In the end, we need the federal

government at the table as a full participant in the process including being able to cast a vote

on a standards issue.
Comments from Schneider Electric to NIST RFI Page 5 of 5

Streamline Methods for Referencing of Standards in Regulations

One of the key advantages to the private sector standards system is its ability to react to

changes in technology and the market and revise standards to keep them relevant to the

current day.  We are fully supportive of using references to standards in regulation as a way to

achieve the regulatory objective.  There is, however, a significant issue with this process.  The

referenced standard becomes outdated and the process for updating to the current edition is

often simply ignored or it then becomes part of the rulemaking process which moves at a pace

where even the updated standard may be replaced by a newer version before the rulemaking is

complete.

One method that should be pursued and has been used in some areas of the government is to

write the regulation in a manner that automatically updates to the most current edition in a set

time period after that edition becomes available.    The regulator could provide public

notification of the update and if no substantive objections are received in that set time period,

then the update would go into effect.  This approach should be applied as the “norm” across all

federal agencies.

Adequacy of Resources

In this area, the government is no different than a corporation.  It takes focused efforts to get

senior levels of management to understand the value and importance of standards activities.  

Agencies where this is not understood will cut standards participation rapidly when budgets are

tightened.   Standards participation is an investment in the future and has to be viewed as such

by the leadership of agencies and corporations alike.  NIST should be given an expanded role in

emphasizing the importance of standards to both policymakers and agency leadership.  One of

the best ways for this to be accomplished is to bring in some of the private sector participants

to talk about the value of standards for commerce and job creation.  Frankly, this same model

can be applied in reverse as well.  Having government participants that are able to talk to the

private sector about the importance of standards to the government will drive better

understanding as well.