policy & advocacy

About Policy & Advocacy

NARUC represents the interests of State public utility commissions before the three branches of the Federal government and the Independent Federal agencies. NARUC provides Members of Congress and their staff with:

  • Association's position on issues being debated in the House or Senate
  • Witnesses to testify before Congressional Committees
  • Policy briefings to update and educate Senate and House staff.

Additionally, NARUC files briefs and pleadings before the U.S. Supreme Court and other Federal courts in support of State utility commission interests. NARUC also provides the Executive Branch with policy proposals and works with the Departments on the formulation of regulatory policies. NARUC works closely with the Federal Energy Regulatory Commission (FERC), the Federal Communications Commission (FCC), and the Nuclear Regulatory Commissioner (NRC), the Securities and Exchange Commission and the Federal Trade Commission to ensure the State perspective is considered in their proceedings.


Latest Work Products

NARUC Opposes Provisions That Eliminate the State "ETC" Designation Process - July 14, 2020

NARUC Endorses S.4021 and opposing provision in similar bill (S.4201) - July 9, 2020

NARUC Supplement to the Record of the June 24th FCC Oversight Hearing

FCC and NARUC Partner to Raise Awareness About Federal Lifeline Program

6 GHz Incumbent Stakeholder Letter

AD16-16 RM19-15 - NARUC PURPA Comments

19 0314 Letter Re: The Water and Energy Research Integration Act of 2019 — H.R. 34

18 1207 Separations Joint Board Recommended Decision

18 1116 NARUC Request to Extend Challenge Window to March 2019

18 1112 NARUC Ex Parte re SEPARATIONS  with Yvette Cage

18 1109 NARUC Ex Parte re SEPARATIONS with Travis Litman

18 1101 NARUC Ex Parte re NORS

18 1016 NARUC Reply IP CTS FNPRM Comments

18 0924 NARUC USAC Re-Nomination Sarah Freeman

18 0918 NARUC Ex Parte re Lifeline Separations PRE contacts

18 0827 Initial NARUC IP CTS FRNPM Comments

18 0911 NARUC Separations Reply Comments

18 0827 Initial NARUC Wireline Comments on Separations

18 0827 Reply NARUC Wireline Comments Natl Verifier

18 0810 Initial NARUC Wireline Comments on National Verifier

18 0622 NARUC Ex Parte on Numbering Resolution

18 0529 NARUC Ex Parte re Lifeline contacts Amy B

18 0406 Letter to FCC on BDAC Composition Kjellander Betkoski

18 0324 NARUC Reply Lifeline NPRM cmts

18 0221 NARUC Initial Lifeline NPRM cmts

18 0215 NARUC Nomination of NY PSC CMR SAYRE TO USF JB 

18 0215 USAC Nomination Sarah Freeman  

NARUC NTIA Privacy Comments

Letter in Internet Freedom Appeal

Letter supporting the Sustainable Water Infrastructure Investment Act of 2018 - S. 3358

NARUC Initial Comments in Response to the FCC's Proposed Extension of the Freeze of Jurisdictional Separations Category Relationships and Cost Allocation Factors

Letter to the Administration Urging the Appointment of State Utility Commissioners to Open Vacancies at FERC and Other Federal Agencies:


NARUC Notice of Ex Parte Communication in the Matter of Lifeline

NARUC's Request for an Extension of the Comment Deadline for the USTelecom Petition for Forbearance

Letter to U.S. Senate Committee on Environment and Public Works Leadership Supporting the Voluntary Water Partnership for Distressed Communities Act

Letter to U.S. Senate and U.S. House Committees on Natural Resources Regarding Disaster Preparedness in Puerto Rico and PREPA and PREC

Joint NARUC/NEI/NWSC Letter to DOE Secretary Rick Perry Re: Nuclear Waste Fund Status Transparency

NARUC’s Request for Rehearing/Clarification of FERC’s Energy Storage Order (Order No. 841; Docket No. RM16-23-000)

Letter to U.S. Senate Leadership in Support of PURPA Reform

NARUC, NEI, and NWSC Letter to DOE Secretary Perry and OMD Director Mulvaney to Express Opposition to Reinstatement of the Uranium Decommissioning and Decontamination Tax

Testimony by Montana PSC Vice Chairman Travis Kavulla Before the U.S. House of Representatives Subcommittee on Energy in Support of the PURPA Modernization Act of 2017 (HR 4476)

NARUC Pushes for PURPA Reform in Letter to FERC

NARUC comments to USTR on Import Injury with Regard to Certain Crystalline Silicon Photovoltaic Cells (USTR-2017-0020)

NARUC comments to FERC on DOE Grid Resiliency Pricing Rule NOPR (RM18-1)

Joint Brief: State Response to Petition for Rehearing En Banc Inmate Calling Rates

Letter to FCC on BDAC Composition

NARUC Letter to the House Energy and Commerce Committee on the Nuclear Waste Policy Amendments Act of 2017

NARUC Initial Comments on the FCC Wireline "Preemption" Proceeding

NARUC NEI NWSC Letter to the Administration Regarding the Uranium Enrichment Decontamination and Decommissioning Fund

NARUC Commissioner O'Donnell letter to Representative Blackburn re: Nuclear Waste Hearing

NARUC Initial Comments on Mobilitie Petition: ERRATA

Final Resolutions Passed at the NARUC Winter 2017 Committee Meetings

NARUC Comments to FERC on Storage and DER Aggregators (RM16-23/AD 16-20)

Letter to House and Senate Leadership Encouraging Congress to Take Action to Stop Implementation of the Final Rule on Waters of the United States (WOTUS)

NARUC vs FCC on the Lifeline Order

NARUC Initial Lifeline Brief

Letter to the Transition Team on the NARUC Role in Presidential Transition

NARUC Letter to the Trump Transition Team on Telecommunications Issues

NARUC Letter to the Trump Transition Team on Energy Issues

NARUC et al. Response to Order to Show Cause to Stay Pending Litigation to Preserve Judicial Economy and the Efficient Resolution of Cases

NARUC Ex Parte Seeking Clarification of Process to correct Carrier Submitted Data

NARUC Nomination of Brise to the FCC’s Intergovernmental Advisory Committee

Case no. 15-1461 Reply Brief of State and Local Petitioners Inmate Calling

NARUC Protest at FERC Against Challenge to VT PURPA Rules (EL17-16)

NARUC Ex Parte to FCC on Lifeline Waivers

Final Resolutions Passed at the 128th NARUC Annual Meeting

NARUC Comments to FERC on PURPA (AD16-16)

Implementation Issues Under the Public Utility Regulatory Policies Act of 1978 (AD16-16-000)

15-4161 et al, Gobal Tel*Link, et al, vs. FCC (Appeal of the FCC’s preemptive Inmate Calling Order) Reply Brief of State and Local Petitioners

NARUC Opposition To FCC Motion to Hold the Case In Abeyance

NARUC Intervention to Oppose Request to Preempt MD PSC Community Solar Net Metering

NARUC Notice of Written Ex Parte from the State Members of the FCC’s Federal State Joint Conference on Advanced Services on State Broadband Policy with Survey Attached

Letter to Senate leadership urging Congress to Prioritize Investment in Water Infrastructure on the September 15, 2016 Observance of “Imagine a Day Without Water”

Letter to House leadership urging Congress to prioritize investment in water infrastructure on the September 15, 2016 observance of “Imagine a Day Without Water”

NARUC et al Petition for Stay of Inmate Calling Reconsideration Order

Joint Reply Comments of the Western Coal Traffic League, American Public Power Association, Edison Electric Institute, National Association of Regulatory Utility Commissioners, National Rural Electric Cooperative Association, and Freight Rail Customer Alliance

NARUC Letter Request for Withdrawal of the Current Rule Defining Waters of the United States (WOTUS) or for Both the EPA and the U.S. Army Corps of Engineers to Propose a Supplemental Rule

Joint NARUC- Coal Shipper Reply Comments in STB EP733 Expediting Railroad Rate Cases

NARUC Amicus Brief in Support of California PUC’s Use of Broadband Data

Letter urging  Congress take action to prevent implementation of the Environmental Protection Agency and Army Corps of Engineers’ final rule redefining the “Waters of the United States”

NARUC Comments to CFTC regarding RTO-ISO Order Proposed Amendment

State/NARUC Opposition to FCC Motion to hold inmate calling appeal in abeyance

NARUC Comment Letter in the Pipeline and Hazardous Materials Safety Administration’s Pipeline Safety: Safety of Gas Transmission and Gathering Pipelines Rulemaking (PHMSA-2011-0023)

Testimony: The Honorable Travis Kavulla, President, National Association of Regulatory Utility Commissioners on Behalf of the National Association of Regulatory Utility Commissioners, Before the United States House of Representatives Committee on Energy and Commerce, Subcommittee on Energy and Power

Joint Reply Comments of the Western Coal Traffic League, American Public Power Association, National Association ff Regulatory Utility Commissioners, National Rural Electric Cooperative Association, and Freight Rail Customer Alliance to the Supplemental Notice of Proposed Rulemaking

NARUC Reply Brief, Petitions for Review of an Order of the Federal Communications Commission (FCC)

State and Local Government Petitioners Petition for Review of Final Agency Action of the FCC

NARUC Petition for Review of Lifeline

Joint Comments of NARUC et al to the supplemental Notice of Proposed Rulemaking

NARUC Letter to FERC Regarding Panelists for Competitive Transmission Technical Conference

Letter to the Senate Commerce, Science and Transportation Committee calling for bipartisan consensus on FCC process reform legislation

NARUC Extension Request Letter to Comment on PHMSA Docket No. PHMSA-2011-0023, Pipeline Safety: Safety of Gas Transmission and Gathering Pipelines

Petitioner Brief Combined with Statutory Addendum for VoIP Access to Numbers

Letter to the FCC in the Matter of Lifeline and Link Up Reform and Modernization

Testimony: Commissioner Saari on "Pipeline Safety Reauthorization Legislation"

NARUC Letter to the Senate Opposing King-Reid Amendment #3120