Advocacy Filings

When government bodies and other organizations consider cases or policy decisions that affect consumers or competition, the FTC may offer insight and expertise to decision makers by filing an advocacy letter. To find a specific filing, use the filters on this page.

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FTC Staff Comment To the Delaware Board of Speech/Language Pathologists, Audiologists and Hearing Aid Dispensers Regarding Its Proposed Revisions To Its Telecommunication and Telehealth Regulations

Matter Number:

V170001

FTC staff submitted a comment to the Delaware Board of Speech/Language Pathologists, Audiologists and Hearing Aid Dispensers on its proposed regulation that would allow telepractice in those fields but require an initial in-person evaluation. Staff stated that allowing telepractice could enhance consumer choice by providing an alternative to in-person care, potentially reducing travel expenditures and increasing both access to care and competition. However, because the proposed regulation requires that all initial evaluations be conducted in person, it may unnecessarily discourage the use of telepractice and limit its potential benefits.

FTC/DOJ Joint Comment to the Federal Energy Regulatory Commission (FERC) Regarding Modifications to FERC Requirements for Review of Certain Transactions and Market-Based Rate Applications

Matter Number:

V170000

Docket Number:

RM16-21-000

The FTC and DOJ submitted a comment to FERC regarding market power in wholesale electricity markets. The comment responds to a FERC request for comments on how it assesses market power with respect to mergers and electricity sales at market-based rates, which it evaluates under the Federal Power Act (FPA). The agencies encouraged FERC not to rely solely on structural indicators of market power, such as market share or concentration, when assessing market power under FPA sections 203 and 205.

Comment of Jessica L. Rich, Director, Bureau of Consumer Protection, to the National Highway Traffic Safety Administration Supporting the Inclusion of Consumer Privacy and Cybersecurity Guidance in the Document “Federal Automated Vehicles Policy”

Matter Number:

P135405

Docket Number:

NHTSA-2016-0090

BCP Director Jessica L. Rich submitted a comment to NHTSA regarding its request for comments on proposed industry guidance for highly automated vehicles. Rich commends NHTSA for its “thoughtful consideration of the emerging issues presented by innovative technologies in vehicles, and the agency’s strong commitment to protect consumer privacy and vehicle cybersecurity in the HAV area.” Rich also commends NHTSA for “includ[ing] recommendations designed to ensure that privacy and security issues are considered throughout the vehicle lifecycle, particularly in the design phase.”

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