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 Before the Massachusetts House of Representatives Regarding House Bill 2009 (H.2009) Concerning Supervisory Requirements for Nurse Practitioners and Nurse Anesthetists

January 2014

Matter Number:

V140002

Staff submitted a comment, in response to a request by Massachusetts State Representative Kay Khan, regarding a bill that would eliminate certain supervision requirements for nurse practitioners and nurse anesthetists. Staff concluded that these changes likely would benefit competition and consumers in Massachusetts. The comment further encouraged the Massachusetts legislature to consider adopting provisions that would permit APRNs to deliver the full range of health care services they are trained and certified to provide.

FTC Staff Comment Before the Massachusetts House of Representatives Regarding House Bill 2009 (H.2009) Concerning Supervisory Requirements for Nurse Practitioners and Nurse Anesthetists (3.18 MB)

FTC Staff Reply Comment Before the District of Columbia Public Service Commission Concerning a Proposed Program for Dynamic (Variable) Pricing of Electricity for Residential Customers, Formal Case Nos. 1086 and 1109

January 2014

Matter Number:

V140001

FTC staff submitted a comment in response to the District of Columbia Public Service Commission’s (DC PSC) request for comments on Potomac Electric Power Company’s (Pepco’s) proposed dynamic pricing program for residential customers. The comment encouraged DC PSC to adopt the proposal as a constructive initial step toward improving the efficiency of the electric system in a way that can benefit many customers, but also leave the existing price structure in place for customers who do not (or cannot) respond to the efficiency incentives. It also recommended that DC PSC periodically review the effects of the proposed approach, with a focus on the accuracy of the price signals being conveyed, consumer participation in and satisfaction with the program, and methods to enhance consumer participation and satisfaction. The comment further recommended that DC PSC ensure that appropriate safeguards are in place with respect to the personal information that smart meters generate about customers and ensure that entities that receive such personal information protect it appropriately.

FTC Staff Reply Comment Before the District of Columbia Public Service Commission Concerning a Proposed Program for Dynamic (Variable) Pricing of Electricity for Residential Customers, Formal Case Nos. 1086 and 1109 (163.17 KB)

FTC Staff Comment Before the Commission on Dental Accreditation Concerning Proposed Accreditation Standards for Dental Therapy Education Programs

December 2013

Matter Number:

V140000

FTC staff filed an advocacy comment with the American Dental Association’s Commission on Dental Accreditation (CODA) regarding proposed accreditation standards for education programs for dental therapists. The comment praised CODA’s proposed accreditation standards for helping to facilitate the development of a nationwide dental therapy profession, but also recommended that CODA omit unnecessary language on supervision and scope of practice, which could constrain the discretion of states to determine dental therapists’ scope of practice and possibly deter innovation in dental care education.

FTC Staff Comment Before the Commission on Dental Accreditation Concerning Proposed Accreditation Standards for Dental Therapy Education Programs (561.04 KB)

FTC Staff Comment Before the Public Service Commission of the State of Delaware Concerning its Proposal to Revised Its Rules for Certification and Regulation of Electric Suppliers

November 2013

Matter Number:

V130011

Docket Number:

FTC staff submitted a comment before the Public Service Commission (PSC) of the State of Delaware, in response to a request for comments on a proposal to revise its rules for certifying and regulating electricity suppliers. The staff comment noted the potential benefits of dynamic pricing, and encouraged the PSC to consider the potential costs associated with a proposal to require electricity suppliers to give customers at least five days’ advance notice of price changes. The comment identified alternatives to a five-day notice period that would provide consumers with the benefits of dynamic pricing via devices such as “smart meters” while assuring that consumers have accurate and timely electricity price information. The comment recommended that, if the PSC chooses to implement such alternatives, it could also require special prominence for disclosures pertaining to price variability and early termination charges in residential retail electricity sales contracts involving variable rates.

FTC Staff Comment Before the Public Service Commission of the State of Delaware Concerning Its Proposal to Revise Its Rules for Certification and Regulation of Electric Suppliers (97.84 KB)

FTC Staff Comment Before The Arizona Corporation Commission Concerning Retail Electric Competition, Docket No. E00000W-13-0135

July 2013

Matter Number:

V130010

Docket Number:

E00000W-13-0135

FTC staff submitted a comment in response to a request from the Arizona Corporation Commission (ACC) for comments on retail electric competition in Arizona. The comment agrees with the ACC that it is timely for Arizona to consider retail competition that would enable consumers to select from specialized power suppliers using metering innovations now widely available in the state. Retail choice can help consumers match their preferences for bill savings, increased reliability, renewable power, and energy management services. For example, consumers can lower their bills by shifting power use away from periods when the power system depends on more costly generation resources or faces challenges to its reliability, and they can choose how much power to consume from renewable generation sources.

FTC Staff Comment Before The Arizona Corporation Commission Concerning Retail Electric Competition, Docket No. E00000W-13-0135 (114.96 KB)