Reader responses to the April 2015 essay, "Certification of Regulatory Professionals: Why Not?":
From Nancy Brockway, NBrockway & Associates
Because certification excludes good professionals and protects bad ones. And it is not needed.
From Marty Cohen, Martin Roth Cohen & Associates
Thanks for writing up this bold and provocative proposal. As a self-taught 30 year participant in the regulatory process (who has served as a consumer advocate, commission chairman (briefly!), expert witness and consultant—all without an advanced degree of any kind—I respond first with questions:
As you know, my views are far from libertarian but I question the purpose of certification in the regulatory process (see first question above). And I’d point out that, while in some professional fields you mentioned (such as pilots and plumbers and dentists) there is clearly a public interest in assuring that nobody practices without a license, for some others certification largely serves to restrict participation by providing a barrier to entry for competitors. In the case of public utility regulatory process there may be even less need for certification than for cosmetologists and barbers because it is the credibility of facts and opinions that is primary in decision making, not the education or standing or demonstrated skill of the individual making the argument. The credibility and background of a witness is always fair game in the adversarial process, as it should be, but cases are decided by the weight of the evidence, not the stature of who is presenting it.
Some of us like it that way.
From Nicholas A. (Nick) Brown, President & Chief Executive Officer, Southwest Power Pool
With regulation charged with protecting the public interest, it only makes sense to me that those involved in the process demonstrate at least some minimal level of expertise to protect that interest. Most important of all these persons are the commissioners.
Here's something to consider in your future discussion: In every strategic planning cycle for SPP over the last 20 years, regulatory turnover is identified as our single largest risk. The turnover rate for the commissioners in our 8 states and at FERC is about 50% every 18 months. The learning curve is steep, industries varied and complex, and turnover high --- OUCH!