The Center for Democracy & Technology ("CDT") and the Electronic Frontier Foundation (“EFF”) are pleased to file these comments in response to the September 17, 2010 Request for Information ("RFI") on "policy and logistical challenges that confront smart grid implementation, as well as recommendations on how to best overcome those challenges."
The RFI focuses in part on the effects on consumers of the implementation of the smart grid. The RFI in particular asks "what role do factors like the trust [and] consumer control ... play in shaping consumer participation in [the smart grid]." Clearly, one of the major concerns for consumers in a smart grid setting will be the privacy and security of their data. Addressing this very real concern now, before the widespread implementation of smart grid technology, will not only prevent misuse of consumers’ information but also give consumers confidence that their data is secure, thereby encouraging adoption of the new technologies. In particular, the RFI seeks comments regarding "what policies are needed to facilitate the data sharing that will allow ... grid automation to achieve [its] potential."