How to read the money
Income and expense are whole-filing amounts associated with this lobbyist, not personal compensation or an allocated share.
No topic inference: each bill number appears in source LDA issue text assigned to this lobbyist.
Investing in Our Communities Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed possible regulations to implement section 26 USC 7701(a)(51)(D)(i)(l)(dd), prohibited foreign entity debt test (15 percent). Discussed support of possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts. Discussed support for elective payment of energy tax credits in the Inflation Reduction Act (26 USC 6817) and the need for clarity from the Treasury Department on the implementation of section 26 USC 7701(a)(51), prohibited foreign entity debt test. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed support for H.R. 1255, the Investing in Our Communities Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed support for potential legislation to increase the $10 million small issue threshold in 26 USC 265(b)(3) to $30 million.
Specific issues are shown only where the LDA source assigned them to this lobbyist. Targets apply to the associated filing.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2026 · second_quarter · Q2
Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 9337, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed H.R. 6633, the High-Capacity Grid Act (all provisions), to establish a best-available transmission conductor standard for certain transmission projects under the Federal Power Act and to provide for presumptions regarding cost recovery for such conductors. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give the Federal Energy Regulatory Commission the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 9332, the Load Forecasting Enhancement Act, to require the Federal Energy Regulatory Commission to establish regional joint boards to study electric load forecasting. Discussed technical assistance for public power utilities for load forecasting. Discussed H.R. 9340, the Ratepayer Protection Act, to amend the Public Utility Regulatory Policies Act of 1978 to establish a federal standard relating to the recovery of the full, incremental costs of upgrades that serve large-load customers (all provisions). Discussed Winter Storm Fern and the use of section 202(c) orders by the Department of Energy to ensure grid reliability. Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Provided feedback on draft legislation, the State Energy Oversight Act, on performance-based ratemaking. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed support for H.R. 8308, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed the importance of coordination between the military and public power utilities that serve them (no legislation). Discussed issues related to defense critical electric infrastructure, including the importance of coordination between the military and Department of Energy (no legislation). Discussed existing cooperative agreements with the Department of Energy (DE-CR0000007, DE-CR0000015, and DE-CR0000026. Discussed the Executive Order on Artificial Intelligence. Discussion of distribution transformer supply chain challenges (no legislation). Discussed the impact of federal trade policies on supply chains for public power utilities (no legislation). Discussed supply chain issues facing public power utilities and the significant cost increases they are seeing for key electrical equipment that can only be acquired abroad (no legislation). Discussed the importance of the Tennessee Valley Authority to public power utilities served by it. Discussed the public power business model (no legislation). Discussed energy affordability and all the actions public power utilities take to keep electricity affordable for their customers and to assist those in need (no legislation). Discussed how public power utilities are working to ensure their customers do not bear the costs of serving large computational loads (no legislation). Discussed issues related to data center affordability and support for efforts to protect affordability and reliability, as well as ensuring a voice for public power in evaluating governance issues (FERC Docket RM26-4 and AD26-7). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives.
Source: Senate LDA
Investing in Our Communities Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed possible regulations to implement section 26 USC 7701(a)(51)(D)(i)(l)(dd), prohibited foreign entity debt test (15 percent). Discussed support for regulations implementing 26 USC 7701(51)(D)(i)(I)(dd) regarding the prohibited foreign entity debt test (15 percent) to exempt publicly offered debt or stipulate that the underwriter of publicly offered debt is the issuee for purposes of the text. Discussed support of possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts and acquisition of existing output facilities to serve large load customers. Discussed support for elective payment of energy tax credits in the Inflation Reduction Act (26 USC 6817). Discussed concerns with implementation of the domestic content requirements necessary to access elective pay provisions in the Inflation Reduction Act (Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702). Discussed support for simplifying the qualification for elective payment under 26 USC 6417 (no legislation). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed support for H.R. 1255, the Investing in Our Communities Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed the importance of municipal bonds, which are used by public power utilities to build energy infrastructure. Discussed support for S. 1481, the Lifting Our Communities through Advanced Liquidity for Infrastructure Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed support for potential legislation to increase the $10 million small issue threshold in 26 USC 265(b)(3) to $30 million. Discussed opposition to proposed changes to tax-exempt financing to encourage the privatization of public infrastructure through asset recycling (no legislation). Discussed the potential effect of energy and natural gas prepayment transactions on tax-exempt financing.
Water Systems PFAS Liability Protection Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 3898, the PERMIT Act, to improve the permitting process for infrastructure projects under the Clean Water Act, the provision regarding nationwide permitting and the determination of the appropriate acreage threshold for discharges into WOTUS, and the provision regarding section 18 statutory exclusion from the regulatory definition of WOTUS for waste treatment systems. Discussed support for H.R. 161, the New Source Review Permitting Improvement Act (all provisions). Discussed H.R. 1267, the PFAS Water Systems Liability Act, regarding how utilities are passive receivers of PFAS. Discussed the technology-based effluent limitations and standards for the Steam Electric Power Generating Point Source that the Environmental Protection Agency (EPA) promulgated in 2024 (RIN: 2040-AG41). Discussed EPAs proposed rule to approve state implementation plans for the 2015 ozone ambient air quality standards based on the agencys conclusion that 10 states dont contribute to downwind state nonattainment (EPA-HQ-OAR-2025-0192).
New Source Review Permitting Improvement Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 3898, the PERMIT Act, to improve the permitting process for infrastructure projects under the Clean Water Act, the provision regarding nationwide permitting and the determination of the appropriate acreage threshold for discharges into WOTUS, and the provision regarding section 18 statutory exclusion from the regulatory definition of WOTUS for waste treatment systems. Discussed support for H.R. 161, the New Source Review Permitting Improvement Act (all provisions). Discussed H.R. 1267, the PFAS Water Systems Liability Act, regarding how utilities are passive receivers of PFAS. Discussed the technology-based effluent limitations and standards for the Steam Electric Power Generating Point Source that the Environmental Protection Agency (EPA) promulgated in 2024 (RIN: 2040-AG41). Discussed EPAs proposed rule to approve state implementation plans for the 2015 ozone ambient air quality standards based on the agencys conclusion that 10 states dont contribute to downwind state nonattainment (EPA-HQ-OAR-2025-0192).
POWER Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 4669, the FEMA Act (all provisions), including section 101 on rebuilding public infrastructure. Discussed support for H.R. 2672, the FEMA Loan Interest Payment Relief Act (all provisions) to provide financial assistance to a local government or electric cooperative as reimbursement for interest paid on a loan used for emergency or disaster recovery activities later paid for by FEMA assistance. Discussed support for its reintroduction in the 119th Congress. Discussed support for H.R. 164, the Promoting Opportunities to Widen Electrical Resilience (POWER) Act of 2025, to authorize electric utilities receiving certain emergency assistance for the restoration of power to also carry out cost-effective hazard mitigation activities in combination with the power restoration activities.
ESA Amendments Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 4776, the SPEED Act, to reform permitting processes under the National Environmental Policy Act (all provisions). Discussed support for H.R. 4503, the ePermit Act, to digitize the federal permitting process for environmental reviews. Discussed support of reforms to the Endangered Species Act that would change the definition of habitat (no legislation). Discussed how the Endangered Species Act impacts energy infrastructure projects (no legislation). Discussed H.R. 1897, the Endangered Species Act Amendments of 2025 (all provisions). Discussed the Environmental Protection Agencys reconsideration of the 2024 Coal Combustion Residuals Legacy rule regarding the disposal of coal combustion residuals and impoundments (RIN: 2050-AH39).
To require the Federal Energy Regulatory Commission to extend the time period during which licensees are required to commence construction of certain hydropower projects.
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the Cybersecurity and Information Security Agencys (CISA) work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for S. 2983, the Protecting America from Cyber Threats Act (all provisions), to reauthorize the Cybersecurity Information Security Act of 2015 (CISA 2015). Discussed support for a replacement to the Critical Infrastructure Partnership Advisory Council at the Department of Homeland Security to facilitate interaction between governmental entities and representatives from the community of critical infrastructure owners and operators. (no legislation). Discussed support for H.R. 7258, the Energy Emergency Leadership Act, to elevate the Department of Energys energy emergency and cybersecurity responsibilities by requiring those critical functions to be led by a Senate-confirmed Assistant Secretary (all provisions). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 2072, the Build More Hydro Act, to require the Federal Energy Regulatory Commission to extend the period during which licensees are required to commence construction of certain hydropower projects (all provisions). Discussed H.R. 7940, the Safeguarding Aquatic Fisheries and Ecosystem (SAFE) Pathways Act, to amend the Federal Power Act to require the consideration of invasive species when prescribing fishways. Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed the role of grid enhancing technologies in transmission and virtual power plants (no legislation). Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed H.R. 7977, the transmission provisions in the Energy Bills Relief Act. Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 3947, the REWIRE Act, section 3, to provide categorical exclusions for transmission projects that increase grid capacity in existing rights-of-way by reconductoring, using grid enhancing technologies, and deploying energy storage, and section 4, to increase return on equity for reconductoring using advanced conductors. Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Discussed H.R. 7329, the Fighting for Reliable Energy and Ending Doubt for Open Markets (FREEDOM) Act, to amend the Energy Act of 2020, the Geothermal Steam Act of 1970, the Energy Policy Act of 2005, and the Mineral Leasing Act to streamline the leasing and permitting processes of federal agencies for certain energy and mineral projects, to clarify federal authorization requirements for certain projects on non-federal land, to establish enforceable federal authorization timelines and expedited judicial remedies, to limit federal actions halting fully permitted projects, to create a de-risking compensation program. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed draft legislation, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed Light Up Navajo project to get electricity to unserved families of the Navajo Nation (no legislation). Discussed ongoing grid hardening activities by public power utilities and needed additional investments (no legislation). Discussed potential federal funding for critical infrastructure hardening. Discussed the impact tariffs are having on public power utilities (no legislation). Discussed the impact of supply chain issues on public power utilities (no legislation). Discussed the impact from data centers on electricity prices to customers in communities that dont have data centers (FERC Docket RM26-4). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives. Discussed wholesale electricity market development efforts in the West. Discussed the public power business model and FERCs jurisdiction over public power utilities under the Federal Power Act.
Maintaining and Enhancing Hydroelectricity and River Restoration Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed possible regulations to implement section 26 USC 7701(a)(51)(D)(i)(l)(dd), prohibited foreign entity debt test (15 percent). Discussed support for regulations implementing 26 USC 7701(51)(D)(i)(I)(dd) regarding the prohibited foreign entity debt test (15 percent) to exempt publicly offered debt or stipulate that the underwriter of publicly offered debt is the issuee for purposes of the text. Discussed support of possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts and acquisition of existing output facilities to serve large load customers. Discussed support for elective payment of energy tax credits in the Inflation Reduction Act (26 USC 6817). Discussed concerns with implementation of the domestic content requirements necessary to access elective pay provisions in the Inflation Reduction Act (Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702). Discussed support for simplifying the qualification for elective payment under 26 USC 6417 (no legislation). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed support for H.R. 1255, the Investing in Our Communities Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed the importance of municipal bonds, which are used by public power utilities to build energy infrastructure. Discussed support for S. 1481, the Lifting Our Communities through Advanced Liquidity for Infrastructure Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed support for potential legislation to increase the $10 million small issue threshold in 26 USC 265(b)(3) to $30 million. Discussed opposition to proposed changes to tax-exempt financing to encourage the privatization of public infrastructure through asset recycling (no legislation). Discussed the potential effect of energy and natural gas prepayment transactions on tax-exempt financing.
Maintaining and Enhancing Hydroelectricity and River Restoration Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the Cybersecurity and Information Security Agencys (CISA) work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for S. 2983, the Protecting America from Cyber Threats Act (all provisions), to reauthorize the Cybersecurity Information Security Act of 2015 (CISA 2015). Discussed support for a replacement to the Critical Infrastructure Partnership Advisory Council at the Department of Homeland Security to facilitate interaction between governmental entities and representatives from the community of critical infrastructure owners and operators. (no legislation). Discussed support for H.R. 7258, the Energy Emergency Leadership Act, to elevate the Department of Energys energy emergency and cybersecurity responsibilities by requiring those critical functions to be led by a Senate-confirmed Assistant Secretary (all provisions). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 2072, the Build More Hydro Act, to require the Federal Energy Regulatory Commission to extend the period during which licensees are required to commence construction of certain hydropower projects (all provisions). Discussed H.R. 7940, the Safeguarding Aquatic Fisheries and Ecosystem (SAFE) Pathways Act, to amend the Federal Power Act to require the consideration of invasive species when prescribing fishways. Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed the role of grid enhancing technologies in transmission and virtual power plants (no legislation). Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed H.R. 7977, the transmission provisions in the Energy Bills Relief Act. Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 3947, the REWIRE Act, section 3, to provide categorical exclusions for transmission projects that increase grid capacity in existing rights-of-way by reconductoring, using grid enhancing technologies, and deploying energy storage, and section 4, to increase return on equity for reconductoring using advanced conductors. Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Discussed H.R. 7329, the Fighting for Reliable Energy and Ending Doubt for Open Markets (FREEDOM) Act, to amend the Energy Act of 2020, the Geothermal Steam Act of 1970, the Energy Policy Act of 2005, and the Mineral Leasing Act to streamline the leasing and permitting processes of federal agencies for certain energy and mineral projects, to clarify federal authorization requirements for certain projects on non-federal land, to establish enforceable federal authorization timelines and expedited judicial remedies, to limit federal actions halting fully permitted projects, to create a de-risking compensation program. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed draft legislation, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed Light Up Navajo project to get electricity to unserved families of the Navajo Nation (no legislation). Discussed ongoing grid hardening activities by public power utilities and needed additional investments (no legislation). Discussed potential federal funding for critical infrastructure hardening. Discussed the impact tariffs are having on public power utilities (no legislation). Discussed the impact of supply chain issues on public power utilities (no legislation). Discussed the impact from data centers on electricity prices to customers in communities that dont have data centers (FERC Docket RM26-4). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives. Discussed wholesale electricity market development efforts in the West. Discussed the public power business model and FERCs jurisdiction over public power utilities under the Federal Power Act.
Maintaining and Enhancing Hydroelectricity and River Restoration Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed possible regulations to implement section 26 USC 7701(a)(51)(D)(i)(l)(dd), prohibited foreign entity debt test (15 percent). Discussed support of possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts. Discussed support for elective payment of energy tax credits in the Inflation Reduction Act (26 USC 6817) and the need for clarity from the Treasury Department on the implementation of section 26 USC 7701(a)(51), prohibited foreign entity debt test. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed support for H.R. 1255, the Investing in Our Communities Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed support for potential legislation to increase the $10 million small issue threshold in 26 USC 265(b)(3) to $30 million.
Southwestern Power Administration Fund Establishment Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed the need for action on categorical exclusions for vegetation management along power line corridors. Also discussed strict liability for utilities operating on public lands for wildfires. Discussed the importance of the federal Power Marketing Administrations that provide federal hydropower to public power utilities and opposition to any attempts to privatize them in whole or in part. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions). Discussed support for the acting commissioner of the Bureau of Reclamation to release funds in the Colorado River Dam Fund for the acquisition of wide head turbines at Hoover Dam as directed to in the report language accompanying H.R. 6938, the Energy & Water Development Appropriations Act, 2026. Discussed the need to exempt the Boulder Canyon Dam Project from the Federal Lands Recreation Enhancement Act (P.L. 108‑447), which would give the Bureau of Reclamation the ability to collect entry fees at Hoover Dam (no legislation).
Religious Workforce Protection Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 4669, the FEMA Act (all provisions), including section 101 on rebuilding public infrastructure. Discussed support for H.R. 2672, the FEMA Loan Interest Payment Relief Act (all provisions) to provide financial assistance to a local government or electric cooperative as reimbursement for interest paid on a loan used for emergency or disaster recovery activities later paid for by FEMA assistance. Discussed support for its reintroduction in the 119th Congress. Discussed support for H.R. 164, the Promoting Opportunities to Widen Electrical Resilience (POWER) Act of 2025, to authorize electric utilities receiving certain emergency assistance for the restoration of power to also carry out cost-effective hazard mitigation activities in combination with the power restoration activities.
Reliable Power Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the Cybersecurity and Information Security Agencys (CISA) work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for S. 2983, the Protecting America from Cyber Threats Act (all provisions), to reauthorize the Cybersecurity Information Security Act of 2015 (CISA 2015). Discussed support for a replacement to the Critical Infrastructure Partnership Advisory Council at the Department of Homeland Security to facilitate interaction between governmental entities and representatives from the community of critical infrastructure owners and operators. (no legislation). Discussed support for H.R. 7258, the Energy Emergency Leadership Act, to elevate the Department of Energys energy emergency and cybersecurity responsibilities by requiring those critical functions to be led by a Senate-confirmed Assistant Secretary (all provisions). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 2072, the Build More Hydro Act, to require the Federal Energy Regulatory Commission to extend the period during which licensees are required to commence construction of certain hydropower projects (all provisions). Discussed H.R. 7940, the Safeguarding Aquatic Fisheries and Ecosystem (SAFE) Pathways Act, to amend the Federal Power Act to require the consideration of invasive species when prescribing fishways. Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed the role of grid enhancing technologies in transmission and virtual power plants (no legislation). Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed H.R. 7977, the transmission provisions in the Energy Bills Relief Act. Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 3947, the REWIRE Act, section 3, to provide categorical exclusions for transmission projects that increase grid capacity in existing rights-of-way by reconductoring, using grid enhancing technologies, and deploying energy storage, and section 4, to increase return on equity for reconductoring using advanced conductors. Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Discussed H.R. 7329, the Fighting for Reliable Energy and Ending Doubt for Open Markets (FREEDOM) Act, to amend the Energy Act of 2020, the Geothermal Steam Act of 1970, the Energy Policy Act of 2005, and the Mineral Leasing Act to streamline the leasing and permitting processes of federal agencies for certain energy and mineral projects, to clarify federal authorization requirements for certain projects on non-federal land, to establish enforceable federal authorization timelines and expedited judicial remedies, to limit federal actions halting fully permitted projects, to create a de-risking compensation program. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed draft legislation, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed Light Up Navajo project to get electricity to unserved families of the Navajo Nation (no legislation). Discussed ongoing grid hardening activities by public power utilities and needed additional investments (no legislation). Discussed potential federal funding for critical infrastructure hardening. Discussed the impact tariffs are having on public power utilities (no legislation). Discussed the impact of supply chain issues on public power utilities (no legislation). Discussed the impact from data centers on electricity prices to customers in communities that dont have data centers (FERC Docket RM26-4). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives. Discussed wholesale electricity market development efforts in the West. Discussed the public power business model and FERCs jurisdiction over public power utilities under the Federal Power Act.
PERMIT Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 3898, the PERMIT Act, to improve the permitting process for infrastructure projects under the Clean Water Act, the provision regarding nationwide permitting and the determination of the appropriate acreage threshold for discharges into WOTUS, and the provision regarding section 18 statutory exclusion from the regulatory definition of WOTUS for waste treatment systems. Discussed support for H.R. 161, the New Source Review Permitting Improvement Act (all provisions). Discussed H.R. 1267, the PFAS Water Systems Liability Act, regarding how utilities are passive receivers of PFAS. Discussed the technology-based effluent limitations and standards for the Steam Electric Power Generating Point Source that the Environmental Protection Agency (EPA) promulgated in 2024 (RIN: 2040-AG41). Discussed EPAs proposed rule to approve state implementation plans for the 2015 ozone ambient air quality standards based on the agencys conclusion that 10 states dont contribute to downwind state nonattainment (EPA-HQ-OAR-2025-0192).
ePermit Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 4776, the SPEED Act, to reform permitting processes under the National Environmental Policy Act (all provisions). Discussed support for H.R. 4503, the ePermit Act, to digitize the federal permitting process for environmental reviews. Discussed support of reforms to the Endangered Species Act that would change the definition of habitat (no legislation). Discussed how the Endangered Species Act impacts energy infrastructure projects (no legislation). Discussed H.R. 1897, the Endangered Species Act Amendments of 2025 (all provisions). Discussed the Environmental Protection Agencys reconsideration of the 2024 Coal Combustion Residuals Legacy rule regarding the disposal of coal combustion residuals and impoundments (RIN: 2050-AH39).
FEMA Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 4669, the FEMA Act (all provisions), including section 101 on rebuilding public infrastructure. Discussed support for H.R. 2672, the FEMA Loan Interest Payment Relief Act (all provisions) to provide financial assistance to a local government or electric cooperative as reimbursement for interest paid on a loan used for emergency or disaster recovery activities later paid for by FEMA assistance. Discussed support for its reintroduction in the 119th Congress. Discussed support for H.R. 164, the Promoting Opportunities to Widen Electrical Resilience (POWER) Act of 2025, to authorize electric utilities receiving certain emergency assistance for the restoration of power to also carry out cost-effective hazard mitigation activities in combination with the power restoration activities.
Fix Our Forests Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed support for agency actions to expedite environmental reviews under the National Environmental Policy Act, Endangered Species Act, and National Historic Preservation Act to reduce the risk of wildfires. Discussed strict liability caps for wildfires on federal lands under the Forest Land Policy and Management Act (P.L. 94-579). Discussed the need for more consistency of land management practices at federal land management agencies, such as U.S. Forest Service and the Bureau of Land Management. Discussed support for comprehensive vegetation management practices along power line corridors on federal lands. Discussed Bonneville Power Administrations role in transmission in the Pacific Northwest (no legislation). Discussed the federal hydropower system in the Pacific Northwest (no legislation). Discussed support for adequate staffing levels at the federal Power Marketing Administrations (no legislation).
Fix Our Forests Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed the need for action on categorical exclusions for vegetation management along power line corridors. Also discussed strict liability for utilities operating on public lands for wildfires. Discussed the importance of the federal Power Marketing Administrations that provide federal hydropower to public power utilities and opposition to any attempts to privatize them in whole or in part. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions). Discussed support for the acting commissioner of the Bureau of Reclamation to release funds in the Colorado River Dam Fund for the acquisition of wide head turbines at Hoover Dam as directed to in the report language accompanying H.R. 6938, the Energy & Water Development Appropriations Act, 2026. Discussed the need to exempt the Boulder Canyon Dam Project from the Federal Lands Recreation Enhancement Act (P.L. 108‑447), which would give the Bureau of Reclamation the ability to collect entry fees at Hoover Dam (no legislation).
SPEED Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 4776, the SPEED Act, to reform permitting processes under the National Environmental Policy Act (all provisions). Discussed support for H.R. 4503, the ePermit Act, to digitize the federal permitting process for environmental reviews. Discussed support of reforms to the Endangered Species Act that would change the definition of habitat (no legislation). Discussed how the Endangered Species Act impacts energy infrastructure projects (no legislation). Discussed H.R. 1897, the Endangered Species Act Amendments of 2025 (all provisions). Discussed the Environmental Protection Agencys reconsideration of the 2024 Coal Combustion Residuals Legacy rule regarding the disposal of coal combustion residuals and impoundments (RIN: 2050-AH39).
Commerce, Justice, Science; Energy and Water Development; and Interior and Environment Appropriations Act, 2026
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed the need for action on categorical exclusions for vegetation management along power line corridors. Also discussed strict liability for utilities operating on public lands for wildfires. Discussed the importance of the federal Power Marketing Administrations that provide federal hydropower to public power utilities and opposition to any attempts to privatize them in whole or in part. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions). Discussed support for the acting commissioner of the Bureau of Reclamation to release funds in the Colorado River Dam Fund for the acquisition of wide head turbines at Hoover Dam as directed to in the report language accompanying H.R. 6938, the Energy & Water Development Appropriations Act, 2026. Discussed the need to exempt the Boulder Canyon Dam Project from the Federal Lands Recreation Enhancement Act (P.L. 108‑447), which would give the Bureau of Reclamation the ability to collect entry fees at Hoover Dam (no legislation).
Homeland Security and Further Additional Continuing Appropriations Act, 2026.
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for increased funding for the Low Income Home Energy Assistance Program and efforts to ensure the timely disbursement of funds to states (LIHEAP)(no legislation). Discussed support for section 4 of H.R. 7147, the Homeland Security and Further Additional Continuing Appropriations Act, 2026, which incorporates by reference the Joint Explanatory Statement that prescribes Federal Emergency Management Agency actions regarding disaster designations, BRIC grants, public assistance payments, and staffing.
Energy Emergency Leadership Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the Cybersecurity and Information Security Agencys (CISA) work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for S. 2983, the Protecting America from Cyber Threats Act (all provisions), to reauthorize the Cybersecurity Information Security Act of 2015 (CISA 2015). Discussed support for a replacement to the Critical Infrastructure Partnership Advisory Council at the Department of Homeland Security to facilitate interaction between governmental entities and representatives from the community of critical infrastructure owners and operators. (no legislation). Discussed support for H.R. 7258, the Energy Emergency Leadership Act, to elevate the Department of Energys energy emergency and cybersecurity responsibilities by requiring those critical functions to be led by a Senate-confirmed Assistant Secretary (all provisions). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 2072, the Build More Hydro Act, to require the Federal Energy Regulatory Commission to extend the period during which licensees are required to commence construction of certain hydropower projects (all provisions). Discussed H.R. 7940, the Safeguarding Aquatic Fisheries and Ecosystem (SAFE) Pathways Act, to amend the Federal Power Act to require the consideration of invasive species when prescribing fishways. Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed the role of grid enhancing technologies in transmission and virtual power plants (no legislation). Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed H.R. 7977, the transmission provisions in the Energy Bills Relief Act. Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 3947, the REWIRE Act, section 3, to provide categorical exclusions for transmission projects that increase grid capacity in existing rights-of-way by reconductoring, using grid enhancing technologies, and deploying energy storage, and section 4, to increase return on equity for reconductoring using advanced conductors. Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Discussed H.R. 7329, the Fighting for Reliable Energy and Ending Doubt for Open Markets (FREEDOM) Act, to amend the Energy Act of 2020, the Geothermal Steam Act of 1970, the Energy Policy Act of 2005, and the Mineral Leasing Act to streamline the leasing and permitting processes of federal agencies for certain energy and mineral projects, to clarify federal authorization requirements for certain projects on non-federal land, to establish enforceable federal authorization timelines and expedited judicial remedies, to limit federal actions halting fully permitted projects, to create a de-risking compensation program. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed draft legislation, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed Light Up Navajo project to get electricity to unserved families of the Navajo Nation (no legislation). Discussed ongoing grid hardening activities by public power utilities and needed additional investments (no legislation). Discussed potential federal funding for critical infrastructure hardening. Discussed the impact tariffs are having on public power utilities (no legislation). Discussed the impact of supply chain issues on public power utilities (no legislation). Discussed the impact from data centers on electricity prices to customers in communities that dont have data centers (FERC Docket RM26-4). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives. Discussed wholesale electricity market development efforts in the West. Discussed the public power business model and FERCs jurisdiction over public power utilities under the Federal Power Act.
Rural and Municipal Utility Cybersecurity Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 9337, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed H.R. 6633, the High-Capacity Grid Act (all provisions), to establish a best-available transmission conductor standard for certain transmission projects under the Federal Power Act and to provide for presumptions regarding cost recovery for such conductors. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give the Federal Energy Regulatory Commission the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 9332, the Load Forecasting Enhancement Act, to require the Federal Energy Regulatory Commission to establish regional joint boards to study electric load forecasting. Discussed technical assistance for public power utilities for load forecasting. Discussed H.R. 9340, the Ratepayer Protection Act, to amend the Public Utility Regulatory Policies Act of 1978 to establish a federal standard relating to the recovery of the full, incremental costs of upgrades that serve large-load customers (all provisions). Discussed Winter Storm Fern and the use of section 202(c) orders by the Department of Energy to ensure grid reliability. Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Provided feedback on draft legislation, the State Energy Oversight Act, on performance-based ratemaking. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed support for H.R. 8308, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed the importance of coordination between the military and public power utilities that serve them (no legislation). Discussed issues related to defense critical electric infrastructure, including the importance of coordination between the military and Department of Energy (no legislation). Discussed existing cooperative agreements with the Department of Energy (DE-CR0000007, DE-CR0000015, and DE-CR0000026. Discussed the Executive Order on Artificial Intelligence. Discussion of distribution transformer supply chain challenges (no legislation). Discussed the impact of federal trade policies on supply chains for public power utilities (no legislation). Discussed supply chain issues facing public power utilities and the significant cost increases they are seeing for key electrical equipment that can only be acquired abroad (no legislation). Discussed the importance of the Tennessee Valley Authority to public power utilities served by it. Discussed the public power business model (no legislation). Discussed energy affordability and all the actions public power utilities take to keep electricity affordable for their customers and to assist those in need (no legislation). Discussed how public power utilities are working to ensure their customers do not bear the costs of serving large computational loads (no legislation). Discussed issues related to data center affordability and support for efforts to protect affordability and reliability, as well as ensuring a voice for public power in evaluating governance issues (FERC Docket RM26-4 and AD26-7). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives.
FREEDOM Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the Cybersecurity and Information Security Agencys (CISA) work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for S. 2983, the Protecting America from Cyber Threats Act (all provisions), to reauthorize the Cybersecurity Information Security Act of 2015 (CISA 2015). Discussed support for a replacement to the Critical Infrastructure Partnership Advisory Council at the Department of Homeland Security to facilitate interaction between governmental entities and representatives from the community of critical infrastructure owners and operators. (no legislation). Discussed support for H.R. 7258, the Energy Emergency Leadership Act, to elevate the Department of Energys energy emergency and cybersecurity responsibilities by requiring those critical functions to be led by a Senate-confirmed Assistant Secretary (all provisions). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 2072, the Build More Hydro Act, to require the Federal Energy Regulatory Commission to extend the period during which licensees are required to commence construction of certain hydropower projects (all provisions). Discussed H.R. 7940, the Safeguarding Aquatic Fisheries and Ecosystem (SAFE) Pathways Act, to amend the Federal Power Act to require the consideration of invasive species when prescribing fishways. Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed the role of grid enhancing technologies in transmission and virtual power plants (no legislation). Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed H.R. 7977, the transmission provisions in the Energy Bills Relief Act. Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 3947, the REWIRE Act, section 3, to provide categorical exclusions for transmission projects that increase grid capacity in existing rights-of-way by reconductoring, using grid enhancing technologies, and deploying energy storage, and section 4, to increase return on equity for reconductoring using advanced conductors. Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Discussed H.R. 7329, the Fighting for Reliable Energy and Ending Doubt for Open Markets (FREEDOM) Act, to amend the Energy Act of 2020, the Geothermal Steam Act of 1970, the Energy Policy Act of 2005, and the Mineral Leasing Act to streamline the leasing and permitting processes of federal agencies for certain energy and mineral projects, to clarify federal authorization requirements for certain projects on non-federal land, to establish enforceable federal authorization timelines and expedited judicial remedies, to limit federal actions halting fully permitted projects, to create a de-risking compensation program. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed draft legislation, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed Light Up Navajo project to get electricity to unserved families of the Navajo Nation (no legislation). Discussed ongoing grid hardening activities by public power utilities and needed additional investments (no legislation). Discussed potential federal funding for critical infrastructure hardening. Discussed the impact tariffs are having on public power utilities (no legislation). Discussed the impact of supply chain issues on public power utilities (no legislation). Discussed the impact from data centers on electricity prices to customers in communities that dont have data centers (FERC Docket RM26-4). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives. Discussed wholesale electricity market development efforts in the West. Discussed the public power business model and FERCs jurisdiction over public power utilities under the Federal Power Act.
AI Fraud Accountability Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the Cybersecurity and Information Security Agencys (CISA) work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for S. 2983, the Protecting America from Cyber Threats Act (all provisions), to reauthorize the Cybersecurity Information Security Act of 2015 (CISA 2015). Discussed support for a replacement to the Critical Infrastructure Partnership Advisory Council at the Department of Homeland Security to facilitate interaction between governmental entities and representatives from the community of critical infrastructure owners and operators. (no legislation). Discussed support for H.R. 7258, the Energy Emergency Leadership Act, to elevate the Department of Energys energy emergency and cybersecurity responsibilities by requiring those critical functions to be led by a Senate-confirmed Assistant Secretary (all provisions). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 2072, the Build More Hydro Act, to require the Federal Energy Regulatory Commission to extend the period during which licensees are required to commence construction of certain hydropower projects (all provisions). Discussed H.R. 7940, the Safeguarding Aquatic Fisheries and Ecosystem (SAFE) Pathways Act, to amend the Federal Power Act to require the consideration of invasive species when prescribing fishways. Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed the role of grid enhancing technologies in transmission and virtual power plants (no legislation). Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed H.R. 7977, the transmission provisions in the Energy Bills Relief Act. Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 3947, the REWIRE Act, section 3, to provide categorical exclusions for transmission projects that increase grid capacity in existing rights-of-way by reconductoring, using grid enhancing technologies, and deploying energy storage, and section 4, to increase return on equity for reconductoring using advanced conductors. Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Discussed H.R. 7329, the Fighting for Reliable Energy and Ending Doubt for Open Markets (FREEDOM) Act, to amend the Energy Act of 2020, the Geothermal Steam Act of 1970, the Energy Policy Act of 2005, and the Mineral Leasing Act to streamline the leasing and permitting processes of federal agencies for certain energy and mineral projects, to clarify federal authorization requirements for certain projects on non-federal land, to establish enforceable federal authorization timelines and expedited judicial remedies, to limit federal actions halting fully permitted projects, to create a de-risking compensation program. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed draft legislation, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed Light Up Navajo project to get electricity to unserved families of the Navajo Nation (no legislation). Discussed ongoing grid hardening activities by public power utilities and needed additional investments (no legislation). Discussed potential federal funding for critical infrastructure hardening. Discussed the impact tariffs are having on public power utilities (no legislation). Discussed the impact of supply chain issues on public power utilities (no legislation). Discussed the impact from data centers on electricity prices to customers in communities that dont have data centers (FERC Docket RM26-4). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives. Discussed wholesale electricity market development efforts in the West. Discussed the public power business model and FERCs jurisdiction over public power utilities under the Federal Power Act.
AI Fraud Accountability Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 9337, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed H.R. 6633, the High-Capacity Grid Act (all provisions), to establish a best-available transmission conductor standard for certain transmission projects under the Federal Power Act and to provide for presumptions regarding cost recovery for such conductors. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give the Federal Energy Regulatory Commission the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 9332, the Load Forecasting Enhancement Act, to require the Federal Energy Regulatory Commission to establish regional joint boards to study electric load forecasting. Discussed technical assistance for public power utilities for load forecasting. Discussed H.R. 9340, the Ratepayer Protection Act, to amend the Public Utility Regulatory Policies Act of 1978 to establish a federal standard relating to the recovery of the full, incremental costs of upgrades that serve large-load customers (all provisions). Discussed Winter Storm Fern and the use of section 202(c) orders by the Department of Energy to ensure grid reliability. Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Provided feedback on draft legislation, the State Energy Oversight Act, on performance-based ratemaking. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed support for H.R. 8308, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed the importance of coordination between the military and public power utilities that serve them (no legislation). Discussed issues related to defense critical electric infrastructure, including the importance of coordination between the military and Department of Energy (no legislation). Discussed existing cooperative agreements with the Department of Energy (DE-CR0000007, DE-CR0000015, and DE-CR0000026. Discussed the Executive Order on Artificial Intelligence. Discussion of distribution transformer supply chain challenges (no legislation). Discussed the impact of federal trade policies on supply chains for public power utilities (no legislation). Discussed supply chain issues facing public power utilities and the significant cost increases they are seeing for key electrical equipment that can only be acquired abroad (no legislation). Discussed the importance of the Tennessee Valley Authority to public power utilities served by it. Discussed the public power business model (no legislation). Discussed energy affordability and all the actions public power utilities take to keep electricity affordable for their customers and to assist those in need (no legislation). Discussed how public power utilities are working to ensure their customers do not bear the costs of serving large computational loads (no legislation). Discussed issues related to data center affordability and support for efforts to protect affordability and reliability, as well as ensuring a voice for public power in evaluating governance issues (FERC Docket RM26-4 and AD26-7). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives.
SAFE Pathways Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the Cybersecurity and Information Security Agencys (CISA) work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for S. 2983, the Protecting America from Cyber Threats Act (all provisions), to reauthorize the Cybersecurity Information Security Act of 2015 (CISA 2015). Discussed support for a replacement to the Critical Infrastructure Partnership Advisory Council at the Department of Homeland Security to facilitate interaction between governmental entities and representatives from the community of critical infrastructure owners and operators. (no legislation). Discussed support for H.R. 7258, the Energy Emergency Leadership Act, to elevate the Department of Energys energy emergency and cybersecurity responsibilities by requiring those critical functions to be led by a Senate-confirmed Assistant Secretary (all provisions). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 2072, the Build More Hydro Act, to require the Federal Energy Regulatory Commission to extend the period during which licensees are required to commence construction of certain hydropower projects (all provisions). Discussed H.R. 7940, the Safeguarding Aquatic Fisheries and Ecosystem (SAFE) Pathways Act, to amend the Federal Power Act to require the consideration of invasive species when prescribing fishways. Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed the role of grid enhancing technologies in transmission and virtual power plants (no legislation). Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed H.R. 7977, the transmission provisions in the Energy Bills Relief Act. Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 3947, the REWIRE Act, section 3, to provide categorical exclusions for transmission projects that increase grid capacity in existing rights-of-way by reconductoring, using grid enhancing technologies, and deploying energy storage, and section 4, to increase return on equity for reconductoring using advanced conductors. Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Discussed H.R. 7329, the Fighting for Reliable Energy and Ending Doubt for Open Markets (FREEDOM) Act, to amend the Energy Act of 2020, the Geothermal Steam Act of 1970, the Energy Policy Act of 2005, and the Mineral Leasing Act to streamline the leasing and permitting processes of federal agencies for certain energy and mineral projects, to clarify federal authorization requirements for certain projects on non-federal land, to establish enforceable federal authorization timelines and expedited judicial remedies, to limit federal actions halting fully permitted projects, to create a de-risking compensation program. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed draft legislation, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed Light Up Navajo project to get electricity to unserved families of the Navajo Nation (no legislation). Discussed ongoing grid hardening activities by public power utilities and needed additional investments (no legislation). Discussed potential federal funding for critical infrastructure hardening. Discussed the impact tariffs are having on public power utilities (no legislation). Discussed the impact of supply chain issues on public power utilities (no legislation). Discussed the impact from data centers on electricity prices to customers in communities that dont have data centers (FERC Docket RM26-4). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives. Discussed wholesale electricity market development efforts in the West. Discussed the public power business model and FERCs jurisdiction over public power utilities under the Federal Power Act.
Energy Bills Relief Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the Cybersecurity and Information Security Agencys (CISA) work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for S. 2983, the Protecting America from Cyber Threats Act (all provisions), to reauthorize the Cybersecurity Information Security Act of 2015 (CISA 2015). Discussed support for a replacement to the Critical Infrastructure Partnership Advisory Council at the Department of Homeland Security to facilitate interaction between governmental entities and representatives from the community of critical infrastructure owners and operators. (no legislation). Discussed support for H.R. 7258, the Energy Emergency Leadership Act, to elevate the Department of Energys energy emergency and cybersecurity responsibilities by requiring those critical functions to be led by a Senate-confirmed Assistant Secretary (all provisions). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 2072, the Build More Hydro Act, to require the Federal Energy Regulatory Commission to extend the period during which licensees are required to commence construction of certain hydropower projects (all provisions). Discussed H.R. 7940, the Safeguarding Aquatic Fisheries and Ecosystem (SAFE) Pathways Act, to amend the Federal Power Act to require the consideration of invasive species when prescribing fishways. Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed the role of grid enhancing technologies in transmission and virtual power plants (no legislation). Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed H.R. 7977, the transmission provisions in the Energy Bills Relief Act. Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 3947, the REWIRE Act, section 3, to provide categorical exclusions for transmission projects that increase grid capacity in existing rights-of-way by reconductoring, using grid enhancing technologies, and deploying energy storage, and section 4, to increase return on equity for reconductoring using advanced conductors. Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Discussed H.R. 7329, the Fighting for Reliable Energy and Ending Doubt for Open Markets (FREEDOM) Act, to amend the Energy Act of 2020, the Geothermal Steam Act of 1970, the Energy Policy Act of 2005, and the Mineral Leasing Act to streamline the leasing and permitting processes of federal agencies for certain energy and mineral projects, to clarify federal authorization requirements for certain projects on non-federal land, to establish enforceable federal authorization timelines and expedited judicial remedies, to limit federal actions halting fully permitted projects, to create a de-risking compensation program. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed draft legislation, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed Light Up Navajo project to get electricity to unserved families of the Navajo Nation (no legislation). Discussed ongoing grid hardening activities by public power utilities and needed additional investments (no legislation). Discussed potential federal funding for critical infrastructure hardening. Discussed the impact tariffs are having on public power utilities (no legislation). Discussed the impact of supply chain issues on public power utilities (no legislation). Discussed the impact from data centers on electricity prices to customers in communities that dont have data centers (FERC Docket RM26-4). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives. Discussed wholesale electricity market development efforts in the West. Discussed the public power business model and FERCs jurisdiction over public power utilities under the Federal Power Act.
Hydropower Licensing Affordability Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 9337, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed H.R. 6633, the High-Capacity Grid Act (all provisions), to establish a best-available transmission conductor standard for certain transmission projects under the Federal Power Act and to provide for presumptions regarding cost recovery for such conductors. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give the Federal Energy Regulatory Commission the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 9332, the Load Forecasting Enhancement Act, to require the Federal Energy Regulatory Commission to establish regional joint boards to study electric load forecasting. Discussed technical assistance for public power utilities for load forecasting. Discussed H.R. 9340, the Ratepayer Protection Act, to amend the Public Utility Regulatory Policies Act of 1978 to establish a federal standard relating to the recovery of the full, incremental costs of upgrades that serve large-load customers (all provisions). Discussed Winter Storm Fern and the use of section 202(c) orders by the Department of Energy to ensure grid reliability. Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Provided feedback on draft legislation, the State Energy Oversight Act, on performance-based ratemaking. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed support for H.R. 8308, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed the importance of coordination between the military and public power utilities that serve them (no legislation). Discussed issues related to defense critical electric infrastructure, including the importance of coordination between the military and Department of Energy (no legislation). Discussed existing cooperative agreements with the Department of Energy (DE-CR0000007, DE-CR0000015, and DE-CR0000026. Discussed the Executive Order on Artificial Intelligence. Discussion of distribution transformer supply chain challenges (no legislation). Discussed the impact of federal trade policies on supply chains for public power utilities (no legislation). Discussed supply chain issues facing public power utilities and the significant cost increases they are seeing for key electrical equipment that can only be acquired abroad (no legislation). Discussed the importance of the Tennessee Valley Authority to public power utilities served by it. Discussed the public power business model (no legislation). Discussed energy affordability and all the actions public power utilities take to keep electricity affordable for their customers and to assist those in need (no legislation). Discussed how public power utilities are working to ensure their customers do not bear the costs of serving large computational loads (no legislation). Discussed issues related to data center affordability and support for efforts to protect affordability and reliability, as well as ensuring a voice for public power in evaluating governance issues (FERC Docket RM26-4 and AD26-7). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives.
Southwestern Power Administration Fund Establishment Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed the need for action on categorical exclusions for vegetation management along power line corridors. Also discussed strict liability for utilities operating on public lands for wildfires. Discussed the importance of the federal Power Marketing Administrations that provide federal hydropower to public power utilities and opposition to any attempts to privatize them in whole or in part. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions). Discussed support for the acting commissioner of the Bureau of Reclamation to release funds in the Colorado River Dam Fund for the acquisition of wide head turbines at Hoover Dam as directed to in the report language accompanying H.R. 6938, the Energy & Water Development Appropriations Act, 2026. Discussed the need to exempt the Boulder Canyon Dam Project from the Federal Lands Recreation Enhancement Act (P.L. 108‑447), which would give the Bureau of Reclamation the ability to collect entry fees at Hoover Dam (no legislation).
Maintaining and Enhancing Hydroelectricity and River Restoration Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the Cybersecurity and Information Security Agencys (CISA) work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for S. 2983, the Protecting America from Cyber Threats Act (all provisions), to reauthorize the Cybersecurity Information Security Act of 2015 (CISA 2015). Discussed support for a replacement to the Critical Infrastructure Partnership Advisory Council at the Department of Homeland Security to facilitate interaction between governmental entities and representatives from the community of critical infrastructure owners and operators. (no legislation). Discussed support for H.R. 7258, the Energy Emergency Leadership Act, to elevate the Department of Energys energy emergency and cybersecurity responsibilities by requiring those critical functions to be led by a Senate-confirmed Assistant Secretary (all provisions). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 2072, the Build More Hydro Act, to require the Federal Energy Regulatory Commission to extend the period during which licensees are required to commence construction of certain hydropower projects (all provisions). Discussed H.R. 7940, the Safeguarding Aquatic Fisheries and Ecosystem (SAFE) Pathways Act, to amend the Federal Power Act to require the consideration of invasive species when prescribing fishways. Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed the role of grid enhancing technologies in transmission and virtual power plants (no legislation). Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed H.R. 7977, the transmission provisions in the Energy Bills Relief Act. Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 3947, the REWIRE Act, section 3, to provide categorical exclusions for transmission projects that increase grid capacity in existing rights-of-way by reconductoring, using grid enhancing technologies, and deploying energy storage, and section 4, to increase return on equity for reconductoring using advanced conductors. Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Discussed H.R. 7329, the Fighting for Reliable Energy and Ending Doubt for Open Markets (FREEDOM) Act, to amend the Energy Act of 2020, the Geothermal Steam Act of 1970, the Energy Policy Act of 2005, and the Mineral Leasing Act to streamline the leasing and permitting processes of federal agencies for certain energy and mineral projects, to clarify federal authorization requirements for certain projects on non-federal land, to establish enforceable federal authorization timelines and expedited judicial remedies, to limit federal actions halting fully permitted projects, to create a de-risking compensation program. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed draft legislation, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed Light Up Navajo project to get electricity to unserved families of the Navajo Nation (no legislation). Discussed ongoing grid hardening activities by public power utilities and needed additional investments (no legislation). Discussed potential federal funding for critical infrastructure hardening. Discussed the impact tariffs are having on public power utilities (no legislation). Discussed the impact of supply chain issues on public power utilities (no legislation). Discussed the impact from data centers on electricity prices to customers in communities that dont have data centers (FERC Docket RM26-4). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives. Discussed wholesale electricity market development efforts in the West. Discussed the public power business model and FERCs jurisdiction over public power utilities under the Federal Power Act.
Maintaining and Enhancing Hydroelectricity and River Restoration Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed possible regulations to implement section 26 USC 7701(a)(51)(D)(i)(l)(dd), prohibited foreign entity debt test (15 percent). Discussed support for regulations implementing 26 USC 7701(51)(D)(i)(I)(dd) regarding the prohibited foreign entity debt test (15 percent) to exempt publicly offered debt or stipulate that the underwriter of publicly offered debt is the issuee for purposes of the text. Discussed support of possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts and acquisition of existing output facilities to serve large load customers. Discussed support for elective payment of energy tax credits in the Inflation Reduction Act (26 USC 6817). Discussed concerns with implementation of the domestic content requirements necessary to access elective pay provisions in the Inflation Reduction Act (Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702). Discussed support for simplifying the qualification for elective payment under 26 USC 6417 (no legislation). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed support for H.R. 1255, the Investing in Our Communities Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed the importance of municipal bonds, which are used by public power utilities to build energy infrastructure. Discussed support for S. 1481, the Lifting Our Communities through Advanced Liquidity for Infrastructure Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed support for potential legislation to increase the $10 million small issue threshold in 26 USC 265(b)(3) to $30 million. Discussed opposition to proposed changes to tax-exempt financing to encourage the privatization of public infrastructure through asset recycling (no legislation). Discussed the potential effect of energy and natural gas prepayment transactions on tax-exempt financing.
Maintaining and Enhancing Hydroelectricity and River Restoration Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed possible regulations to implement section 26 USC 7701(a)(51)(D)(i)(l)(dd), prohibited foreign entity debt test (15 percent). Discussed support of possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts. Discussed support for elective payment of energy tax credits in the Inflation Reduction Act (26 USC 6817) and the need for clarity from the Treasury Department on the implementation of section 26 USC 7701(a)(51), prohibited foreign entity debt test. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed support for H.R. 1255, the Investing in Our Communities Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed support for potential legislation to increase the $10 million small issue threshold in 26 USC 265(b)(3) to $30 million.
Fix Our Forests Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed support for agency actions to expedite environmental reviews under the National Environmental Policy Act, Endangered Species Act, and National Historic Preservation Act to reduce the risk of wildfires. Discussed strict liability caps for wildfires on federal lands under the Forest Land Policy and Management Act (P.L. 94-579). Discussed the need for more consistency of land management practices at federal land management agencies, such as U.S. Forest Service and the Bureau of Land Management. Discussed support for comprehensive vegetation management practices along power line corridors on federal lands. Discussed Bonneville Power Administrations role in transmission in the Pacific Northwest (no legislation). Discussed the federal hydropower system in the Pacific Northwest (no legislation). Discussed support for adequate staffing levels at the federal Power Marketing Administrations (no legislation).
Fix Our Forests Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed the need for action on categorical exclusions for vegetation management along power line corridors. Also discussed strict liability for utilities operating on public lands for wildfires. Discussed the importance of the federal Power Marketing Administrations that provide federal hydropower to public power utilities and opposition to any attempts to privatize them in whole or in part. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions). Discussed support for the acting commissioner of the Bureau of Reclamation to release funds in the Colorado River Dam Fund for the acquisition of wide head turbines at Hoover Dam as directed to in the report language accompanying H.R. 6938, the Energy & Water Development Appropriations Act, 2026. Discussed the need to exempt the Boulder Canyon Dam Project from the Federal Lands Recreation Enhancement Act (P.L. 108‑447), which would give the Bureau of Reclamation the ability to collect entry fees at Hoover Dam (no legislation).
LOCAL Infrastructure Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed possible regulations to implement section 26 USC 7701(a)(51)(D)(i)(l)(dd), prohibited foreign entity debt test (15 percent). Discussed support for regulations implementing 26 USC 7701(51)(D)(i)(I)(dd) regarding the prohibited foreign entity debt test (15 percent) to exempt publicly offered debt or stipulate that the underwriter of publicly offered debt is the issuee for purposes of the text. Discussed support of possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts and acquisition of existing output facilities to serve large load customers. Discussed support for elective payment of energy tax credits in the Inflation Reduction Act (26 USC 6817). Discussed concerns with implementation of the domestic content requirements necessary to access elective pay provisions in the Inflation Reduction Act (Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702). Discussed support for simplifying the qualification for elective payment under 26 USC 6417 (no legislation). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed support for H.R. 1255, the Investing in Our Communities Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed the importance of municipal bonds, which are used by public power utilities to build energy infrastructure. Discussed support for S. 1481, the Lifting Our Communities through Advanced Liquidity for Infrastructure Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed support for potential legislation to increase the $10 million small issue threshold in 26 USC 265(b)(3) to $30 million. Discussed opposition to proposed changes to tax-exempt financing to encourage the privatization of public infrastructure through asset recycling (no legislation). Discussed the potential effect of energy and natural gas prepayment transactions on tax-exempt financing.
Reliable Power Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the Cybersecurity and Information Security Agencys (CISA) work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for S. 2983, the Protecting America from Cyber Threats Act (all provisions), to reauthorize the Cybersecurity Information Security Act of 2015 (CISA 2015). Discussed support for a replacement to the Critical Infrastructure Partnership Advisory Council at the Department of Homeland Security to facilitate interaction between governmental entities and representatives from the community of critical infrastructure owners and operators. (no legislation). Discussed support for H.R. 7258, the Energy Emergency Leadership Act, to elevate the Department of Energys energy emergency and cybersecurity responsibilities by requiring those critical functions to be led by a Senate-confirmed Assistant Secretary (all provisions). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 2072, the Build More Hydro Act, to require the Federal Energy Regulatory Commission to extend the period during which licensees are required to commence construction of certain hydropower projects (all provisions). Discussed H.R. 7940, the Safeguarding Aquatic Fisheries and Ecosystem (SAFE) Pathways Act, to amend the Federal Power Act to require the consideration of invasive species when prescribing fishways. Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed the role of grid enhancing technologies in transmission and virtual power plants (no legislation). Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed H.R. 7977, the transmission provisions in the Energy Bills Relief Act. Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 3947, the REWIRE Act, section 3, to provide categorical exclusions for transmission projects that increase grid capacity in existing rights-of-way by reconductoring, using grid enhancing technologies, and deploying energy storage, and section 4, to increase return on equity for reconductoring using advanced conductors. Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Discussed H.R. 7329, the Fighting for Reliable Energy and Ending Doubt for Open Markets (FREEDOM) Act, to amend the Energy Act of 2020, the Geothermal Steam Act of 1970, the Energy Policy Act of 2005, and the Mineral Leasing Act to streamline the leasing and permitting processes of federal agencies for certain energy and mineral projects, to clarify federal authorization requirements for certain projects on non-federal land, to establish enforceable federal authorization timelines and expedited judicial remedies, to limit federal actions halting fully permitted projects, to create a de-risking compensation program. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed draft legislation, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed Light Up Navajo project to get electricity to unserved families of the Navajo Nation (no legislation). Discussed ongoing grid hardening activities by public power utilities and needed additional investments (no legislation). Discussed potential federal funding for critical infrastructure hardening. Discussed the impact tariffs are having on public power utilities (no legislation). Discussed the impact of supply chain issues on public power utilities (no legislation). Discussed the impact from data centers on electricity prices to customers in communities that dont have data centers (FERC Docket RM26-4). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives. Discussed wholesale electricity market development efforts in the West. Discussed the public power business model and FERCs jurisdiction over public power utilities under the Federal Power Act.
Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 9337, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed H.R. 6633, the High-Capacity Grid Act (all provisions), to establish a best-available transmission conductor standard for certain transmission projects under the Federal Power Act and to provide for presumptions regarding cost recovery for such conductors. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give the Federal Energy Regulatory Commission the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 9332, the Load Forecasting Enhancement Act, to require the Federal Energy Regulatory Commission to establish regional joint boards to study electric load forecasting. Discussed technical assistance for public power utilities for load forecasting. Discussed H.R. 9340, the Ratepayer Protection Act, to amend the Public Utility Regulatory Policies Act of 1978 to establish a federal standard relating to the recovery of the full, incremental costs of upgrades that serve large-load customers (all provisions). Discussed Winter Storm Fern and the use of section 202(c) orders by the Department of Energy to ensure grid reliability. Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Provided feedback on draft legislation, the State Energy Oversight Act, on performance-based ratemaking. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed support for H.R. 8308, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed the importance of coordination between the military and public power utilities that serve them (no legislation). Discussed issues related to defense critical electric infrastructure, including the importance of coordination between the military and Department of Energy (no legislation). Discussed existing cooperative agreements with the Department of Energy (DE-CR0000007, DE-CR0000015, and DE-CR0000026. Discussed the Executive Order on Artificial Intelligence. Discussion of distribution transformer supply chain challenges (no legislation). Discussed the impact of federal trade policies on supply chains for public power utilities (no legislation). Discussed supply chain issues facing public power utilities and the significant cost increases they are seeing for key electrical equipment that can only be acquired abroad (no legislation). Discussed the importance of the Tennessee Valley Authority to public power utilities served by it. Discussed the public power business model (no legislation). Discussed energy affordability and all the actions public power utilities take to keep electricity affordable for their customers and to assist those in need (no legislation). Discussed how public power utilities are working to ensure their customers do not bear the costs of serving large computational loads (no legislation). Discussed issues related to data center affordability and support for efforts to protect affordability and reliability, as well as ensuring a voice for public power in evaluating governance issues (FERC Docket RM26-4 and AD26-7). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives.
Discussed the Cybersecurity and Information Security Agencys (CISA) work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for S. 2983, the Protecting America from Cyber Threats Act (all provisions), to reauthorize the Cybersecurity Information Security Act of 2015 (CISA 2015). Discussed support for a replacement to the Critical Infrastructure Partnership Advisory Council at the Department of Homeland Security to facilitate interaction between governmental entities and representatives from the community of critical infrastructure owners and operators. (no legislation). Discussed support for H.R. 7258, the Energy Emergency Leadership Act, to elevate the Department of Energys energy emergency and cybersecurity responsibilities by requiring those critical functions to be led by a Senate-confirmed Assistant Secretary (all provisions). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 2072, the Build More Hydro Act, to require the Federal Energy Regulatory Commission to extend the period during which licensees are required to commence construction of certain hydropower projects (all provisions). Discussed H.R. 7940, the Safeguarding Aquatic Fisheries and Ecosystem (SAFE) Pathways Act, to amend the Federal Power Act to require the consideration of invasive species when prescribing fishways. Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed the role of grid enhancing technologies in transmission and virtual power plants (no legislation). Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed H.R. 7977, the transmission provisions in the Energy Bills Relief Act. Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 3947, the REWIRE Act, section 3, to provide categorical exclusions for transmission projects that increase grid capacity in existing rights-of-way by reconductoring, using grid enhancing technologies, and deploying energy storage, and section 4, to increase return on equity for reconductoring using advanced conductors. Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Discussed H.R. 7329, the Fighting for Reliable Energy and Ending Doubt for Open Markets (FREEDOM) Act, to amend the Energy Act of 2020, the Geothermal Steam Act of 1970, the Energy Policy Act of 2005, and the Mineral Leasing Act to streamline the leasing and permitting processes of federal agencies for certain energy and mineral projects, to clarify federal authorization requirements for certain projects on non-federal land, to establish enforceable federal authorization timelines and expedited judicial remedies, to limit federal actions halting fully permitted projects, to create a de-risking compensation program. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed draft legislation, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed Light Up Navajo project to get electricity to unserved families of the Navajo Nation (no legislation). Discussed ongoing grid hardening activities by public power utilities and needed additional investments (no legislation). Discussed potential federal funding for critical infrastructure hardening. Discussed the impact tariffs are having on public power utilities (no legislation). Discussed the impact of supply chain issues on public power utilities (no legislation). Discussed the impact from data centers on electricity prices to customers in communities that dont have data centers (FERC Docket RM26-4). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives. Discussed wholesale electricity market development efforts in the West. Discussed the public power business model and FERCs jurisdiction over public power utilities under the Federal Power Act.
REWIRE Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the Cybersecurity and Information Security Agencys (CISA) work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for S. 2983, the Protecting America from Cyber Threats Act (all provisions), to reauthorize the Cybersecurity Information Security Act of 2015 (CISA 2015). Discussed support for a replacement to the Critical Infrastructure Partnership Advisory Council at the Department of Homeland Security to facilitate interaction between governmental entities and representatives from the community of critical infrastructure owners and operators. (no legislation). Discussed support for H.R. 7258, the Energy Emergency Leadership Act, to elevate the Department of Energys energy emergency and cybersecurity responsibilities by requiring those critical functions to be led by a Senate-confirmed Assistant Secretary (all provisions). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 2072, the Build More Hydro Act, to require the Federal Energy Regulatory Commission to extend the period during which licensees are required to commence construction of certain hydropower projects (all provisions). Discussed H.R. 7940, the Safeguarding Aquatic Fisheries and Ecosystem (SAFE) Pathways Act, to amend the Federal Power Act to require the consideration of invasive species when prescribing fishways. Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed the role of grid enhancing technologies in transmission and virtual power plants (no legislation). Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed H.R. 7977, the transmission provisions in the Energy Bills Relief Act. Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 3947, the REWIRE Act, section 3, to provide categorical exclusions for transmission projects that increase grid capacity in existing rights-of-way by reconductoring, using grid enhancing technologies, and deploying energy storage, and section 4, to increase return on equity for reconductoring using advanced conductors. Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Discussed H.R. 7329, the Fighting for Reliable Energy and Ending Doubt for Open Markets (FREEDOM) Act, to amend the Energy Act of 2020, the Geothermal Steam Act of 1970, the Energy Policy Act of 2005, and the Mineral Leasing Act to streamline the leasing and permitting processes of federal agencies for certain energy and mineral projects, to clarify federal authorization requirements for certain projects on non-federal land, to establish enforceable federal authorization timelines and expedited judicial remedies, to limit federal actions halting fully permitted projects, to create a de-risking compensation program. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed draft legislation, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed Light Up Navajo project to get electricity to unserved families of the Navajo Nation (no legislation). Discussed ongoing grid hardening activities by public power utilities and needed additional investments (no legislation). Discussed potential federal funding for critical infrastructure hardening. Discussed the impact tariffs are having on public power utilities (no legislation). Discussed the impact of supply chain issues on public power utilities (no legislation). Discussed the impact from data centers on electricity prices to customers in communities that dont have data centers (FERC Docket RM26-4). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives. Discussed wholesale electricity market development efforts in the West. Discussed the public power business model and FERCs jurisdiction over public power utilities under the Federal Power Act.
Guam Emergency Alert System Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the Cybersecurity and Information Security Agencys (CISA) work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for S. 2983, the Protecting America from Cyber Threats Act (all provisions), to reauthorize the Cybersecurity Information Security Act of 2015 (CISA 2015). Discussed support for a replacement to the Critical Infrastructure Partnership Advisory Council at the Department of Homeland Security to facilitate interaction between governmental entities and representatives from the community of critical infrastructure owners and operators. (no legislation). Discussed support for H.R. 7258, the Energy Emergency Leadership Act, to elevate the Department of Energys energy emergency and cybersecurity responsibilities by requiring those critical functions to be led by a Senate-confirmed Assistant Secretary (all provisions). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 2072, the Build More Hydro Act, to require the Federal Energy Regulatory Commission to extend the period during which licensees are required to commence construction of certain hydropower projects (all provisions). Discussed H.R. 7940, the Safeguarding Aquatic Fisheries and Ecosystem (SAFE) Pathways Act, to amend the Federal Power Act to require the consideration of invasive species when prescribing fishways. Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed the role of grid enhancing technologies in transmission and virtual power plants (no legislation). Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed H.R. 7977, the transmission provisions in the Energy Bills Relief Act. Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 3947, the REWIRE Act, section 3, to provide categorical exclusions for transmission projects that increase grid capacity in existing rights-of-way by reconductoring, using grid enhancing technologies, and deploying energy storage, and section 4, to increase return on equity for reconductoring using advanced conductors. Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Discussed H.R. 7329, the Fighting for Reliable Energy and Ending Doubt for Open Markets (FREEDOM) Act, to amend the Energy Act of 2020, the Geothermal Steam Act of 1970, the Energy Policy Act of 2005, and the Mineral Leasing Act to streamline the leasing and permitting processes of federal agencies for certain energy and mineral projects, to clarify federal authorization requirements for certain projects on non-federal land, to establish enforceable federal authorization timelines and expedited judicial remedies, to limit federal actions halting fully permitted projects, to create a de-risking compensation program. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed draft legislation, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed Light Up Navajo project to get electricity to unserved families of the Navajo Nation (no legislation). Discussed ongoing grid hardening activities by public power utilities and needed additional investments (no legislation). Discussed potential federal funding for critical infrastructure hardening. Discussed the impact tariffs are having on public power utilities (no legislation). Discussed the impact of supply chain issues on public power utilities (no legislation). Discussed the impact from data centers on electricity prices to customers in communities that dont have data centers (FERC Docket RM26-4). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives. Discussed wholesale electricity market development efforts in the West. Discussed the public power business model and FERCs jurisdiction over public power utilities under the Federal Power Act.
To designate the facility of the United States Postal Service located at 9355 113th Street in Seminole, Florida, as the "Army SSG Ryan Christian Knauss Memorial Post Office Building".
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 9337, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed H.R. 6633, the High-Capacity Grid Act (all provisions), to establish a best-available transmission conductor standard for certain transmission projects under the Federal Power Act and to provide for presumptions regarding cost recovery for such conductors. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give the Federal Energy Regulatory Commission the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 9332, the Load Forecasting Enhancement Act, to require the Federal Energy Regulatory Commission to establish regional joint boards to study electric load forecasting. Discussed technical assistance for public power utilities for load forecasting. Discussed H.R. 9340, the Ratepayer Protection Act, to amend the Public Utility Regulatory Policies Act of 1978 to establish a federal standard relating to the recovery of the full, incremental costs of upgrades that serve large-load customers (all provisions). Discussed Winter Storm Fern and the use of section 202(c) orders by the Department of Energy to ensure grid reliability. Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Provided feedback on draft legislation, the State Energy Oversight Act, on performance-based ratemaking. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed support for H.R. 8308, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed the importance of coordination between the military and public power utilities that serve them (no legislation). Discussed issues related to defense critical electric infrastructure, including the importance of coordination between the military and Department of Energy (no legislation). Discussed existing cooperative agreements with the Department of Energy (DE-CR0000007, DE-CR0000015, and DE-CR0000026. Discussed the Executive Order on Artificial Intelligence. Discussion of distribution transformer supply chain challenges (no legislation). Discussed the impact of federal trade policies on supply chains for public power utilities (no legislation). Discussed supply chain issues facing public power utilities and the significant cost increases they are seeing for key electrical equipment that can only be acquired abroad (no legislation). Discussed the importance of the Tennessee Valley Authority to public power utilities served by it. Discussed the public power business model (no legislation). Discussed energy affordability and all the actions public power utilities take to keep electricity affordable for their customers and to assist those in need (no legislation). Discussed how public power utilities are working to ensure their customers do not bear the costs of serving large computational loads (no legislation). Discussed issues related to data center affordability and support for efforts to protect affordability and reliability, as well as ensuring a voice for public power in evaluating governance issues (FERC Docket RM26-4 and AD26-7). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives.
Energy Permitting Reform Act of 2024
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the Cybersecurity and Information Security Agencys (CISA) work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for S. 2983, the Protecting America from Cyber Threats Act (all provisions), to reauthorize the Cybersecurity Information Security Act of 2015 (CISA 2015). Discussed support for a replacement to the Critical Infrastructure Partnership Advisory Council at the Department of Homeland Security to facilitate interaction between governmental entities and representatives from the community of critical infrastructure owners and operators. (no legislation). Discussed support for H.R. 7258, the Energy Emergency Leadership Act, to elevate the Department of Energys energy emergency and cybersecurity responsibilities by requiring those critical functions to be led by a Senate-confirmed Assistant Secretary (all provisions). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 2072, the Build More Hydro Act, to require the Federal Energy Regulatory Commission to extend the period during which licensees are required to commence construction of certain hydropower projects (all provisions). Discussed H.R. 7940, the Safeguarding Aquatic Fisheries and Ecosystem (SAFE) Pathways Act, to amend the Federal Power Act to require the consideration of invasive species when prescribing fishways. Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed the role of grid enhancing technologies in transmission and virtual power plants (no legislation). Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed H.R. 7977, the transmission provisions in the Energy Bills Relief Act. Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 3947, the REWIRE Act, section 3, to provide categorical exclusions for transmission projects that increase grid capacity in existing rights-of-way by reconductoring, using grid enhancing technologies, and deploying energy storage, and section 4, to increase return on equity for reconductoring using advanced conductors. Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Discussed H.R. 7329, the Fighting for Reliable Energy and Ending Doubt for Open Markets (FREEDOM) Act, to amend the Energy Act of 2020, the Geothermal Steam Act of 1970, the Energy Policy Act of 2005, and the Mineral Leasing Act to streamline the leasing and permitting processes of federal agencies for certain energy and mineral projects, to clarify federal authorization requirements for certain projects on non-federal land, to establish enforceable federal authorization timelines and expedited judicial remedies, to limit federal actions halting fully permitted projects, to create a de-risking compensation program. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed draft legislation, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed Light Up Navajo project to get electricity to unserved families of the Navajo Nation (no legislation). Discussed ongoing grid hardening activities by public power utilities and needed additional investments (no legislation). Discussed potential federal funding for critical infrastructure hardening. Discussed the impact tariffs are having on public power utilities (no legislation). Discussed the impact of supply chain issues on public power utilities (no legislation). Discussed the impact from data centers on electricity prices to customers in communities that dont have data centers (FERC Docket RM26-4). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives. Discussed wholesale electricity market development efforts in the West. Discussed the public power business model and FERCs jurisdiction over public power utilities under the Federal Power Act.
Energy Permitting Reform Act of 2024
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 9337, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed H.R. 6633, the High-Capacity Grid Act (all provisions), to establish a best-available transmission conductor standard for certain transmission projects under the Federal Power Act and to provide for presumptions regarding cost recovery for such conductors. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give the Federal Energy Regulatory Commission the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 9332, the Load Forecasting Enhancement Act, to require the Federal Energy Regulatory Commission to establish regional joint boards to study electric load forecasting. Discussed technical assistance for public power utilities for load forecasting. Discussed H.R. 9340, the Ratepayer Protection Act, to amend the Public Utility Regulatory Policies Act of 1978 to establish a federal standard relating to the recovery of the full, incremental costs of upgrades that serve large-load customers (all provisions). Discussed Winter Storm Fern and the use of section 202(c) orders by the Department of Energy to ensure grid reliability. Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Provided feedback on draft legislation, the State Energy Oversight Act, on performance-based ratemaking. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed support for H.R. 8308, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed the importance of coordination between the military and public power utilities that serve them (no legislation). Discussed issues related to defense critical electric infrastructure, including the importance of coordination between the military and Department of Energy (no legislation). Discussed existing cooperative agreements with the Department of Energy (DE-CR0000007, DE-CR0000015, and DE-CR0000026. Discussed the Executive Order on Artificial Intelligence. Discussion of distribution transformer supply chain challenges (no legislation). Discussed the impact of federal trade policies on supply chains for public power utilities (no legislation). Discussed supply chain issues facing public power utilities and the significant cost increases they are seeing for key electrical equipment that can only be acquired abroad (no legislation). Discussed the importance of the Tennessee Valley Authority to public power utilities served by it. Discussed the public power business model (no legislation). Discussed energy affordability and all the actions public power utilities take to keep electricity affordable for their customers and to assist those in need (no legislation). Discussed how public power utilities are working to ensure their customers do not bear the costs of serving large computational loads (no legislation). Discussed issues related to data center affordability and support for efforts to protect affordability and reliability, as well as ensuring a voice for public power in evaluating governance issues (FERC Docket RM26-4 and AD26-7). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives.
To amend the Federal Insecticide, Fungicide, and Rodenticide Act to prohibit the local regulation of pesticide use, and for other purposes.
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the Cybersecurity and Information Security Agencys (CISA) work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for S. 2983, the Protecting America from Cyber Threats Act (all provisions), to reauthorize the Cybersecurity Information Security Act of 2015 (CISA 2015). Discussed support for a replacement to the Critical Infrastructure Partnership Advisory Council at the Department of Homeland Security to facilitate interaction between governmental entities and representatives from the community of critical infrastructure owners and operators. (no legislation). Discussed support for H.R. 7258, the Energy Emergency Leadership Act, to elevate the Department of Energys energy emergency and cybersecurity responsibilities by requiring those critical functions to be led by a Senate-confirmed Assistant Secretary (all provisions). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 2072, the Build More Hydro Act, to require the Federal Energy Regulatory Commission to extend the period during which licensees are required to commence construction of certain hydropower projects (all provisions). Discussed H.R. 7940, the Safeguarding Aquatic Fisheries and Ecosystem (SAFE) Pathways Act, to amend the Federal Power Act to require the consideration of invasive species when prescribing fishways. Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed the role of grid enhancing technologies in transmission and virtual power plants (no legislation). Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed H.R. 7977, the transmission provisions in the Energy Bills Relief Act. Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 3947, the REWIRE Act, section 3, to provide categorical exclusions for transmission projects that increase grid capacity in existing rights-of-way by reconductoring, using grid enhancing technologies, and deploying energy storage, and section 4, to increase return on equity for reconductoring using advanced conductors. Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Discussed H.R. 7329, the Fighting for Reliable Energy and Ending Doubt for Open Markets (FREEDOM) Act, to amend the Energy Act of 2020, the Geothermal Steam Act of 1970, the Energy Policy Act of 2005, and the Mineral Leasing Act to streamline the leasing and permitting processes of federal agencies for certain energy and mineral projects, to clarify federal authorization requirements for certain projects on non-federal land, to establish enforceable federal authorization timelines and expedited judicial remedies, to limit federal actions halting fully permitted projects, to create a de-risking compensation program. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed draft legislation, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed Light Up Navajo project to get electricity to unserved families of the Navajo Nation (no legislation). Discussed ongoing grid hardening activities by public power utilities and needed additional investments (no legislation). Discussed potential federal funding for critical infrastructure hardening. Discussed the impact tariffs are having on public power utilities (no legislation). Discussed the impact of supply chain issues on public power utilities (no legislation). Discussed the impact from data centers on electricity prices to customers in communities that dont have data centers (FERC Docket RM26-4). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives. Discussed wholesale electricity market development efforts in the West. Discussed the public power business model and FERCs jurisdiction over public power utilities under the Federal Power Act.
ADAPT for COVID Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the Cybersecurity and Information Security Agencys (CISA) work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for S. 2983, the Protecting America from Cyber Threats Act (all provisions), to reauthorize the Cybersecurity Information Security Act of 2015 (CISA 2015). Discussed support for a replacement to the Critical Infrastructure Partnership Advisory Council at the Department of Homeland Security to facilitate interaction between governmental entities and representatives from the community of critical infrastructure owners and operators. (no legislation). Discussed support for H.R. 7258, the Energy Emergency Leadership Act, to elevate the Department of Energys energy emergency and cybersecurity responsibilities by requiring those critical functions to be led by a Senate-confirmed Assistant Secretary (all provisions). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 2072, the Build More Hydro Act, to require the Federal Energy Regulatory Commission to extend the period during which licensees are required to commence construction of certain hydropower projects (all provisions). Discussed H.R. 7940, the Safeguarding Aquatic Fisheries and Ecosystem (SAFE) Pathways Act, to amend the Federal Power Act to require the consideration of invasive species when prescribing fishways. Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed the role of grid enhancing technologies in transmission and virtual power plants (no legislation). Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed H.R. 7977, the transmission provisions in the Energy Bills Relief Act. Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 3947, the REWIRE Act, section 3, to provide categorical exclusions for transmission projects that increase grid capacity in existing rights-of-way by reconductoring, using grid enhancing technologies, and deploying energy storage, and section 4, to increase return on equity for reconductoring using advanced conductors. Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Discussed H.R. 7329, the Fighting for Reliable Energy and Ending Doubt for Open Markets (FREEDOM) Act, to amend the Energy Act of 2020, the Geothermal Steam Act of 1970, the Energy Policy Act of 2005, and the Mineral Leasing Act to streamline the leasing and permitting processes of federal agencies for certain energy and mineral projects, to clarify federal authorization requirements for certain projects on non-federal land, to establish enforceable federal authorization timelines and expedited judicial remedies, to limit federal actions halting fully permitted projects, to create a de-risking compensation program. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed draft legislation, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed Light Up Navajo project to get electricity to unserved families of the Navajo Nation (no legislation). Discussed ongoing grid hardening activities by public power utilities and needed additional investments (no legislation). Discussed potential federal funding for critical infrastructure hardening. Discussed the impact tariffs are having on public power utilities (no legislation). Discussed the impact of supply chain issues on public power utilities (no legislation). Discussed the impact from data centers on electricity prices to customers in communities that dont have data centers (FERC Docket RM26-4). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives. Discussed wholesale electricity market development efforts in the West. Discussed the public power business model and FERCs jurisdiction over public power utilities under the Federal Power Act.
Establishing the congressional budget for the United States Government for fiscal year 2025 and setting forth the appropriate budgetary levels for fiscal years 2026 through 2034.
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed opposition to potential budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 to amend, in whole or in part, 26 USC 6817, elective payment of energy tax credits. Discussed support for possible legislation to amend 26 USC 6417, elective payment of energy tax credits. Discussed opposition to possible guidance superseding IRS Notice 2013-29, defining beginning of construction for purposes of designating a qualifying facility for certain clean energy projects. Discussed support of possible guidance relating to 26 USC 45U, existing nuclear tax credit, and 26 USC 7701(51)(a), prohibited foreign entity debt test. Discussed the need for the Treasury Department to issue 45U tax guidance for existing nuclear tax credits (no legislation). Discussed possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts. Discussed support for possible regulations to implement section 26 USC 7701(a)(51), prohibited foreign entity debt test. Discussed support for possible regulations to 26 USC 6417, elective payment of energy tax credits. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed support for possible legislation to waiver 2 USC 20A, Statutory Pay-as-You-Go, in relation to the budget effects of P.L. 119-21, the One Big, Beautiful Bill Act of 2025.
Establishing the congressional budget for the United States Government for fiscal year 2025 and setting forth the appropriate budgetary levels for fiscal years 2026 through 2034.
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 6817, elective payment of energy tax credits. Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed opposition to potential budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed opposition to potential budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 to amend, in whole or in part, 26 USC 6817, elective payment of energy tax credits. Discussed support for striking section 70512(f), Elimination of Exception from Phaseout for Elective Payment, from the Senate Finance Committee budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 (concurrent resolution on the budget for fiscal year 2025). Discussed opposition to Senate Finance Committee budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 (concurrent resolution on the budget for fiscal year 2025) section 70513(b) (restrictions relating to prohibited foreign entities) provision requiring publicly held debt to be tested for ownership by specified foreign entities. Discussed opposition to H.R. 1, section 70513(b) (restrictions relating to prohibited foreign entities) as passed by the House, provision requiring publicly held debt to be tested for ownership by specified foreign entities. Discussed opposition to section 70512(f), Termination for Wind and Solar Facilities, ending the production tax credits for projects placed in service after 2027, and section 70513(a), Termination for Wind and Solar Facilities, ending the production tax credits for projects placed in service after 2027, in Senate amendment 2360, (the Senate Budget Committee Amendment to H.R. 1). Discussed support for striking section 70512(f), Elimination of Exception from Phaseout for Elective Payment, from Senate amendment 2360, (the Senate Budget Committee Amendment to H.R. 1). Discussed Elective Pay Blueprint APPA developed for APPA members to guide them on energy tax credits. Discussed support for S. 1481, the LOCAL Infrastructure Act, to reinstate advance refunding bonds. Discussed support for S. 5212, the Enhanced Energy Recovery Act, provisions ensuring tax credits for expanding carbon capture are available via elective payment.
An act to provide for reconciliation pursuant to title II of H. Con. Res. 14.
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 6817, elective payment of energy tax credits. Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed opposition to potential budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed opposition to potential budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 to amend, in whole or in part, 26 USC 6817, elective payment of energy tax credits. Discussed support for striking section 70512(f), Elimination of Exception from Phaseout for Elective Payment, from the Senate Finance Committee budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 (concurrent resolution on the budget for fiscal year 2025). Discussed opposition to Senate Finance Committee budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 (concurrent resolution on the budget for fiscal year 2025) section 70513(b) (restrictions relating to prohibited foreign entities) provision requiring publicly held debt to be tested for ownership by specified foreign entities. Discussed opposition to H.R. 1, section 70513(b) (restrictions relating to prohibited foreign entities) as passed by the House, provision requiring publicly held debt to be tested for ownership by specified foreign entities. Discussed opposition to section 70512(f), Termination for Wind and Solar Facilities, ending the production tax credits for projects placed in service after 2027, and section 70513(a), Termination for Wind and Solar Facilities, ending the production tax credits for projects placed in service after 2027, in Senate amendment 2360, (the Senate Budget Committee Amendment to H.R. 1). Discussed support for striking section 70512(f), Elimination of Exception from Phaseout for Elective Payment, from Senate amendment 2360, (the Senate Budget Committee Amendment to H.R. 1). Discussed Elective Pay Blueprint APPA developed for APPA members to guide them on energy tax credits. Discussed support for S. 1481, the LOCAL Infrastructure Act, to reinstate advance refunding bonds. Discussed support for S. 5212, the Enhanced Energy Recovery Act, provisions ensuring tax credits for expanding carbon capture are available via elective payment.
To provide for a memorandum of understanding to address the impacts of a certain record of decision on the Upper Colorado River Basin Fund.
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the importance of maintaining adequate staffing levels at the Power Marketing Administrations (no legislation). Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund. Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed support for H.R. 1001, to provide for a memorandum of understanding to address the impacts of a certain record of decision on the Upper Colorado River Basin Fund. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed draft legislation to amend the Forest Land Policy and Management Act (P.L. 94-579) to amend strict liability caps for wildfires on federal lands.
GRID Power Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the public power business model. Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed the implementation of Rural and Municipal Advanced Cybersecurity Grant Technical Assistance Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58). Discussed support for S. 448, the Credit Incentives for Resilient Critical Utility Infrastructure and Transformers (CIRCUIT) Act to provide tax credits to the manufacturers of distribution transformers (all provisions). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed draft language to not require licensees to obtain approval for non-substantive alterations or additions at hydropower facilities, routine maintenance, or replacement of hydropower projects that are in response to circumstances beyond their reasonable control. (no legislation). Discussed support for S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed energy tax credits for hydropower (no legislation). Discussed concerns with Form EIA-112, Residential Utility Disconnections Survey (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would exempt Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed interconnection queue reform efforts (no legislation). Discussed H.R. 1047/S. 465, the GRID Power Act to direct the Federal Energy Regulatory Commission to reform the interconnection queue process for the prioritization and approval of certain projects (all provisions). Discussed concerns with transmission affordability and rising transmission costs, and support for policies, such as joint ownership and eliminating unnecessary incentives, that would reduce transmission costs (no legislation). Discussed the importance of maintaining grid reliability and resource adequacy issues. Also discussed of electricity affordability for all customers (no legislation). Discussed the potential impact of federal funding freezes (no legislation). Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort.
GRID Power Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the public power business model. Discussed the role of the Electricity Subsector Coordinating Council (ESCC) and the need for Critical Infrastructure Partnership Advisory Council (CIPAC) protections that allow the ESCC to be operational. Discussed the importance of the Federal Emergency Management Agency (FEMA) in coordinating the response to federal disasters and the restoration of electricity after such disasters. Discussed the upcoming hurricane season and the importance of the Department of Energy (DOE) as a partner in the mutual aid response given federal waivers and exemptions authority primarily resides in the Office of Cybersecurity, Energy Security, and Emergency Response within DOE. Discussed APPAs involvement with the Energy Threat Analysis Center. Discussed support for the reauthorization of the Cybersecurity and Information Security Act of 2015 (passed as Division N of P.L. 114-113) and provisions to maintain public power utilities inclusion in the definition of private entity in section 102(15)(B) and maintaining public power utilities inclusion in section 104(B) - Exemption from Disclosure. Discussed the importance of the Rural and Municipal Advanced Cybersecurity Grant Technical Assistance Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58) to help smaller public power utilities with their cybersecurity posture. Discussed concerns with proposed rescissions of funding for the RMUC Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58). Discussed how public power utilities are utilizing the Grid Resilience and Innovation Partnerships (GRIP) Program to enhance grid reliability and affordability in their communities. Discussed APPA support for the GRIP Program and protecting obligated funds from potential rescissions (no legislation). Discussed support for S. 448, the Credit Incentives for Resilient Critical Utility Infrastructure and Transformers (CIRCUIT) Act to provide tax credits to the manufacturers of distribution transformers (all provisions). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed the importance of hydropower to the electric grid and reliability. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed draft appropriations report language for DOE to study the feasibility of federal technical assistance and regional planning to meet local and regional energy goals. Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed congressional oversight of the interconnection queue process (no legislation). Discussed the need for more flexibility for Federal Energy Regulatory Commission (FERC) and regional transmission organizations in prioritizing interconnection queues based on regional needs rather than resource attributes. Discussed H.R. 1047/S. 465, the GRID Power Act, to direct FERC to reform the interconnection queue process for the prioritization and approval of certain projects (all provisions). Discussed support for H.R. 3616, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (pre-introduction and post-introduction of legislation). Discussed draft legislation, the State Energy Accountability Act, to create a new Public Utility Regulatory Policies Act (PURPA) section 111(d) must-consider requirement to require state regulatory authorities that implement an intermittent energy policy to considering conducting and making public an evaluation of the policys impact on reliability, including during extreme weather, and affordability, among other impacts. Discussed draft legislation, the State Planning for Reliability and Affordability Act, to require utilities to establish sufficient reliable generation facilities to ensure the availability of electric energy over a 10-year period as part of integrated resource planning. Discussed the importance of maintaining grid reliability and resource adequacy issues. Also discussed the importance of electricity affordability for all customers (no legislation). Discussed public powers concerns about transmission affordability, including transmission incentives. Discussed FERCs concerns about resource adequacy and the results of recent capacity auctions. Discussed the importance of reliability, including coordination between the gas and electricity sectors. Discussed the impact of changing tariffs on supply chains for electric utilities (no legislation). Discussed the importance of the Tennessee Valley Authority in providing affordable and reliable power to the Tennessee Valley.
Investing in Our Communities Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the importance of elective pay refundable energy tax credits included in the Inflation Reduction Act (Pub. Law 117-169) for public power investments in clean energy technologies and expressed concerns with any legislative efforts to eliminate them. Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed concerns with implementation of the domestic content requirements necessary to access elective pay provisions in the Inflation Reduction Act (Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702). Discussed tax credits for hydropower (no legislation). Discussed support for H.R. 1255, the Investing in Our Communities Act, to reinstate the ability to issue tax-exempt advanced refunding bonds.
Maintaining and Enhancing Hydroelectricity and River Restoration Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed opposition to potential budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 to amend, in whole or in part, 26 USC 6817, elective payment of energy tax credits. Discussed support for possible legislation to amend 26 USC 6417, elective payment of energy tax credits. Discussed opposition to possible guidance superseding IRS Notice 2013-29, defining beginning of construction for purposes of designating a qualifying facility for certain clean energy projects. Discussed support of possible guidance relating to 26 USC 45U, existing nuclear tax credit, and 26 USC 7701(51)(a), prohibited foreign entity debt test. Discussed the need for the Treasury Department to issue 45U tax guidance for existing nuclear tax credits (no legislation). Discussed possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts. Discussed support for possible regulations to implement section 26 USC 7701(a)(51), prohibited foreign entity debt test. Discussed support for possible regulations to 26 USC 6417, elective payment of energy tax credits. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed support for possible legislation to waiver 2 USC 20A, Statutory Pay-as-You-Go, in relation to the budget effects of P.L. 119-21, the One Big, Beautiful Bill Act of 2025.
Maintaining and Enhancing Hydroelectricity and River Restoration Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the public power business model. Discussed the role of the Electricity Subsector Coordinating Council (ESCC) and the need for Critical Infrastructure Partnership Advisory Council (CIPAC) protections that allow the ESCC to be operational. Discussed the importance of the Federal Emergency Management Agency (FEMA) in coordinating the response to federal disasters and the restoration of electricity after such disasters. Discussed the upcoming hurricane season and the importance of the Department of Energy (DOE) as a partner in the mutual aid response given federal waivers and exemptions authority primarily resides in the Office of Cybersecurity, Energy Security, and Emergency Response within DOE. Discussed APPAs involvement with the Energy Threat Analysis Center. Discussed support for the reauthorization of the Cybersecurity and Information Security Act of 2015 (passed as Division N of P.L. 114-113) and provisions to maintain public power utilities inclusion in the definition of private entity in section 102(15)(B) and maintaining public power utilities inclusion in section 104(B) - Exemption from Disclosure. Discussed the importance of the Rural and Municipal Advanced Cybersecurity Grant Technical Assistance Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58) to help smaller public power utilities with their cybersecurity posture. Discussed concerns with proposed rescissions of funding for the RMUC Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58). Discussed how public power utilities are utilizing the Grid Resilience and Innovation Partnerships (GRIP) Program to enhance grid reliability and affordability in their communities. Discussed APPA support for the GRIP Program and protecting obligated funds from potential rescissions (no legislation). Discussed support for S. 448, the Credit Incentives for Resilient Critical Utility Infrastructure and Transformers (CIRCUIT) Act to provide tax credits to the manufacturers of distribution transformers (all provisions). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed the importance of hydropower to the electric grid and reliability. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed draft appropriations report language for DOE to study the feasibility of federal technical assistance and regional planning to meet local and regional energy goals. Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed congressional oversight of the interconnection queue process (no legislation). Discussed the need for more flexibility for Federal Energy Regulatory Commission (FERC) and regional transmission organizations in prioritizing interconnection queues based on regional needs rather than resource attributes. Discussed H.R. 1047/S. 465, the GRID Power Act, to direct FERC to reform the interconnection queue process for the prioritization and approval of certain projects (all provisions). Discussed support for H.R. 3616, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (pre-introduction and post-introduction of legislation). Discussed draft legislation, the State Energy Accountability Act, to create a new Public Utility Regulatory Policies Act (PURPA) section 111(d) must-consider requirement to require state regulatory authorities that implement an intermittent energy policy to considering conducting and making public an evaluation of the policys impact on reliability, including during extreme weather, and affordability, among other impacts. Discussed draft legislation, the State Planning for Reliability and Affordability Act, to require utilities to establish sufficient reliable generation facilities to ensure the availability of electric energy over a 10-year period as part of integrated resource planning. Discussed the importance of maintaining grid reliability and resource adequacy issues. Also discussed the importance of electricity affordability for all customers (no legislation). Discussed public powers concerns about transmission affordability, including transmission incentives. Discussed FERCs concerns about resource adequacy and the results of recent capacity auctions. Discussed the importance of reliability, including coordination between the gas and electricity sectors. Discussed the impact of changing tariffs on supply chains for electric utilities (no legislation). Discussed the importance of the Tennessee Valley Authority in providing affordable and reliable power to the Tennessee Valley.
Southwestern Power Administration Fund Establishment Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed support for agency actions to expedite environmental reviews under NEPA, the Endangered Species Act, and National Historic Preservation Act to reduce the risk of wildfires. Discussed strict liability caps for wildfires on federal lands under the Forest Land Policy and Management Act (P.L. 94-579). Discussed the need for more consistency of land management practices at federal land management agencies, such as U.S. Forest Service and the Bureau of Land Management. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions).
Help Hoover Dam Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the importance of maintaining adequate staffing levels at the Power Marketing Administrations (no legislation). Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund. Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed support for H.R. 1001, to provide for a memorandum of understanding to address the impacts of a certain record of decision on the Upper Colorado River Basin Fund. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed draft legislation to amend the Forest Land Policy and Management Act (P.L. 94-579) to amend strict liability caps for wildfires on federal lands.
Help Hoover Dam Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed support for agency actions to expedite environmental reviews under NEPA, the Endangered Species Act, and National Historic Preservation Act to reduce the risk of wildfires. Discussed strict liability caps for wildfires on federal lands under the Forest Land Policy and Management Act (P.L. 94-579). Discussed the need for more consistency of land management practices at federal land management agencies, such as U.S. Forest Service and the Bureau of Land Management. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions).
Reliable Power Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed CISAs work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed concerns with the creation of additional cyber incident reporting requirements for electric utilities (no legislation). Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Also discussed extending the availability of existing funds and qualifications for awards. Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities. Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616, the Reliable Power Act, to give the Federal Energy Regulatory Commission (FERC) the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 3843, the Baseline Reliability Protection Act (all provisions), to prohibit retirements of baseload electric generating units in any area that is served by a Regional Transmission Organization or an Independent System Operator and that the North American Electric Reliability Corporation categorizes as at elevated risk or high risk of electricity supply shortfalls. Discussed resource adequacy issues and the importance of grid reliability (no legislation). Discussed H.R. 3699, the Energy Choice Act, to prohibit states or local governments from prohibiting or limiting the connection, reconnection, modification, installation, transportation, distribution, or expansion of an energy service based on the type or source of energy to be delivered (all provisions). Discussed how public power utilities, both transmission owners and transmission dependent, interact with FERC, participate in wholesale electricity markets, and other regional planning bodies (no legislation). Discussed the Department of Energys Speed to Power Initiative and the importance of resource adequacy for grid reliability. Discussed the impact tariffs are having on public power utilities (no legislation).
Reliable Power Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed potential legislation regarding the Energy Threat Analysis Center and obstacles to increased public power participation. Discussed support for the reauthorization of the Cybersecurity and Information Security Act of 2015 (passed as Division N of P.L. 114-113) and provisions to maintain public power utilities inclusion in the definition of private entity in section 102(15)(B) and maintaining public power utilities inclusion in section 104(B) - Exemption from Disclosure. Discussed the urgent need for a replacement for the public disclosure exemptions that were provided under the Critical Infrastructure Partnership Advisory Council to facilitate information sharing at Electricity Subsector Coordinating Council meetings (no legislation). Discussed CISAs work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for S. 1337, the Cybersecurity Information Sharing Extension Act (all provisions). Discussed support for H.R. 5079, the Widespread Information Management for the Welfare of Infrastructure and Government Act (all provisions). Discussed concerns with the creation of additional cyber incident reporting requirements for electric utilities (no legislation). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed support of H.R. 3657, the Hydropower Licensing Transparency Act, to direct the Federal Energy Regulatory Commission (FERC) to report annually to Congress on the status of the relicensing process for each application for a renewed hydropower dam license. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, from the 118th Congress, which would have expanded the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would have exempted Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed grid-enhancing technologies (GETS) and interconnection queue reform. Also discussed the need to ensure savings related to GETS benefits public power utilities and their customers (no bill). Discussed support for H.R. 3616, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Provided feedback on a draft bill to create a new must consider provision under section 111(d) of the Public Utility Regulatory Policy Act that would seek to create interconnection procedures to support microgrids. Discussed public powers concerns about transmission affordability, including transmission incentives. Discussed FERCs concerns about resource adequacy and the results of recent capacity auctions, including issues in Docket AD25-7. Discussed the importance of reliability, including coordination between the gas and electricity sectors. Discussed the North American Electric Reliability Corporations (NERC) electric reliability standards development procedures and the impact of FERC Order No. 907 (directing modifications to NERCs critical infrastructure protection standards) on the prioritization of NERCs standards development work. Discussed the importance of the Tennessee Valley Authority in providing affordable and reliable power to the Tennessee Valley.
Reliable Power Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the public power business model. Discussed the role of the Electricity Subsector Coordinating Council (ESCC) and the need for Critical Infrastructure Partnership Advisory Council (CIPAC) protections that allow the ESCC to be operational. Discussed the importance of the Federal Emergency Management Agency (FEMA) in coordinating the response to federal disasters and the restoration of electricity after such disasters. Discussed the upcoming hurricane season and the importance of the Department of Energy (DOE) as a partner in the mutual aid response given federal waivers and exemptions authority primarily resides in the Office of Cybersecurity, Energy Security, and Emergency Response within DOE. Discussed APPAs involvement with the Energy Threat Analysis Center. Discussed support for the reauthorization of the Cybersecurity and Information Security Act of 2015 (passed as Division N of P.L. 114-113) and provisions to maintain public power utilities inclusion in the definition of private entity in section 102(15)(B) and maintaining public power utilities inclusion in section 104(B) - Exemption from Disclosure. Discussed the importance of the Rural and Municipal Advanced Cybersecurity Grant Technical Assistance Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58) to help smaller public power utilities with their cybersecurity posture. Discussed concerns with proposed rescissions of funding for the RMUC Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58). Discussed how public power utilities are utilizing the Grid Resilience and Innovation Partnerships (GRIP) Program to enhance grid reliability and affordability in their communities. Discussed APPA support for the GRIP Program and protecting obligated funds from potential rescissions (no legislation). Discussed support for S. 448, the Credit Incentives for Resilient Critical Utility Infrastructure and Transformers (CIRCUIT) Act to provide tax credits to the manufacturers of distribution transformers (all provisions). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed the importance of hydropower to the electric grid and reliability. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed draft appropriations report language for DOE to study the feasibility of federal technical assistance and regional planning to meet local and regional energy goals. Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed congressional oversight of the interconnection queue process (no legislation). Discussed the need for more flexibility for Federal Energy Regulatory Commission (FERC) and regional transmission organizations in prioritizing interconnection queues based on regional needs rather than resource attributes. Discussed H.R. 1047/S. 465, the GRID Power Act, to direct FERC to reform the interconnection queue process for the prioritization and approval of certain projects (all provisions). Discussed support for H.R. 3616, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (pre-introduction and post-introduction of legislation). Discussed draft legislation, the State Energy Accountability Act, to create a new Public Utility Regulatory Policies Act (PURPA) section 111(d) must-consider requirement to require state regulatory authorities that implement an intermittent energy policy to considering conducting and making public an evaluation of the policys impact on reliability, including during extreme weather, and affordability, among other impacts. Discussed draft legislation, the State Planning for Reliability and Affordability Act, to require utilities to establish sufficient reliable generation facilities to ensure the availability of electric energy over a 10-year period as part of integrated resource planning. Discussed the importance of maintaining grid reliability and resource adequacy issues. Also discussed the importance of electricity affordability for all customers (no legislation). Discussed public powers concerns about transmission affordability, including transmission incentives. Discussed FERCs concerns about resource adequacy and the results of recent capacity auctions. Discussed the importance of reliability, including coordination between the gas and electricity sectors. Discussed the impact of changing tariffs on supply chains for electric utilities (no legislation). Discussed the importance of the Tennessee Valley Authority in providing affordable and reliable power to the Tennessee Valley.
Energy Choice Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed CISAs work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed concerns with the creation of additional cyber incident reporting requirements for electric utilities (no legislation). Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Also discussed extending the availability of existing funds and qualifications for awards. Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities. Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616, the Reliable Power Act, to give the Federal Energy Regulatory Commission (FERC) the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 3843, the Baseline Reliability Protection Act (all provisions), to prohibit retirements of baseload electric generating units in any area that is served by a Regional Transmission Organization or an Independent System Operator and that the North American Electric Reliability Corporation categorizes as at elevated risk or high risk of electricity supply shortfalls. Discussed resource adequacy issues and the importance of grid reliability (no legislation). Discussed H.R. 3699, the Energy Choice Act, to prohibit states or local governments from prohibiting or limiting the connection, reconnection, modification, installation, transportation, distribution, or expansion of an energy service based on the type or source of energy to be delivered (all provisions). Discussed how public power utilities, both transmission owners and transmission dependent, interact with FERC, participate in wholesale electricity markets, and other regional planning bodies (no legislation). Discussed the Department of Energys Speed to Power Initiative and the importance of resource adequacy for grid reliability. Discussed the impact tariffs are having on public power utilities (no legislation).
Baseload Reliability Protection Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed CISAs work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed concerns with the creation of additional cyber incident reporting requirements for electric utilities (no legislation). Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Also discussed extending the availability of existing funds and qualifications for awards. Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities. Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616, the Reliable Power Act, to give the Federal Energy Regulatory Commission (FERC) the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 3843, the Baseline Reliability Protection Act (all provisions), to prohibit retirements of baseload electric generating units in any area that is served by a Regional Transmission Organization or an Independent System Operator and that the North American Electric Reliability Corporation categorizes as at elevated risk or high risk of electricity supply shortfalls. Discussed resource adequacy issues and the importance of grid reliability (no legislation). Discussed H.R. 3699, the Energy Choice Act, to prohibit states or local governments from prohibiting or limiting the connection, reconnection, modification, installation, transportation, distribution, or expansion of an energy service based on the type or source of energy to be delivered (all provisions). Discussed how public power utilities, both transmission owners and transmission dependent, interact with FERC, participate in wholesale electricity markets, and other regional planning bodies (no legislation). Discussed the Department of Energys Speed to Power Initiative and the importance of resource adequacy for grid reliability. Discussed the impact tariffs are having on public power utilities (no legislation).
Vietnam Veteran Commemoration Fund Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed CISAs work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed concerns with the creation of additional cyber incident reporting requirements for electric utilities (no legislation). Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Also discussed extending the availability of existing funds and qualifications for awards. Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities. Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616, the Reliable Power Act, to give the Federal Energy Regulatory Commission (FERC) the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 3843, the Baseline Reliability Protection Act (all provisions), to prohibit retirements of baseload electric generating units in any area that is served by a Regional Transmission Organization or an Independent System Operator and that the North American Electric Reliability Corporation categorizes as at elevated risk or high risk of electricity supply shortfalls. Discussed resource adequacy issues and the importance of grid reliability (no legislation). Discussed H.R. 3699, the Energy Choice Act, to prohibit states or local governments from prohibiting or limiting the connection, reconnection, modification, installation, transportation, distribution, or expansion of an energy service based on the type or source of energy to be delivered (all provisions). Discussed how public power utilities, both transmission owners and transmission dependent, interact with FERC, participate in wholesale electricity markets, and other regional planning bodies (no legislation). Discussed the Department of Energys Speed to Power Initiative and the importance of resource adequacy for grid reliability. Discussed the impact tariffs are having on public power utilities (no legislation).
Vietnam Veteran Commemoration Fund Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the public power business model. Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed the implementation of Rural and Municipal Advanced Cybersecurity Grant Technical Assistance Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58). Discussed support for S. 448, the Credit Incentives for Resilient Critical Utility Infrastructure and Transformers (CIRCUIT) Act to provide tax credits to the manufacturers of distribution transformers (all provisions). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed draft language to not require licensees to obtain approval for non-substantive alterations or additions at hydropower facilities, routine maintenance, or replacement of hydropower projects that are in response to circumstances beyond their reasonable control. (no legislation). Discussed support for S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed energy tax credits for hydropower (no legislation). Discussed concerns with Form EIA-112, Residential Utility Disconnections Survey (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would exempt Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed interconnection queue reform efforts (no legislation). Discussed H.R. 1047/S. 465, the GRID Power Act to direct the Federal Energy Regulatory Commission to reform the interconnection queue process for the prioritization and approval of certain projects (all provisions). Discussed concerns with transmission affordability and rising transmission costs, and support for policies, such as joint ownership and eliminating unnecessary incentives, that would reduce transmission costs (no legislation). Discussed the importance of maintaining grid reliability and resource adequacy issues. Also discussed of electricity affordability for all customers (no legislation). Discussed the potential impact of federal funding freezes (no legislation). Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort.
Vietnam Veteran Commemoration Fund Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the public power business model. Discussed the role of the Electricity Subsector Coordinating Council (ESCC) and the need for Critical Infrastructure Partnership Advisory Council (CIPAC) protections that allow the ESCC to be operational. Discussed the importance of the Federal Emergency Management Agency (FEMA) in coordinating the response to federal disasters and the restoration of electricity after such disasters. Discussed the upcoming hurricane season and the importance of the Department of Energy (DOE) as a partner in the mutual aid response given federal waivers and exemptions authority primarily resides in the Office of Cybersecurity, Energy Security, and Emergency Response within DOE. Discussed APPAs involvement with the Energy Threat Analysis Center. Discussed support for the reauthorization of the Cybersecurity and Information Security Act of 2015 (passed as Division N of P.L. 114-113) and provisions to maintain public power utilities inclusion in the definition of private entity in section 102(15)(B) and maintaining public power utilities inclusion in section 104(B) - Exemption from Disclosure. Discussed the importance of the Rural and Municipal Advanced Cybersecurity Grant Technical Assistance Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58) to help smaller public power utilities with their cybersecurity posture. Discussed concerns with proposed rescissions of funding for the RMUC Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58). Discussed how public power utilities are utilizing the Grid Resilience and Innovation Partnerships (GRIP) Program to enhance grid reliability and affordability in their communities. Discussed APPA support for the GRIP Program and protecting obligated funds from potential rescissions (no legislation). Discussed support for S. 448, the Credit Incentives for Resilient Critical Utility Infrastructure and Transformers (CIRCUIT) Act to provide tax credits to the manufacturers of distribution transformers (all provisions). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed the importance of hydropower to the electric grid and reliability. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed draft appropriations report language for DOE to study the feasibility of federal technical assistance and regional planning to meet local and regional energy goals. Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed congressional oversight of the interconnection queue process (no legislation). Discussed the need for more flexibility for Federal Energy Regulatory Commission (FERC) and regional transmission organizations in prioritizing interconnection queues based on regional needs rather than resource attributes. Discussed H.R. 1047/S. 465, the GRID Power Act, to direct FERC to reform the interconnection queue process for the prioritization and approval of certain projects (all provisions). Discussed support for H.R. 3616, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (pre-introduction and post-introduction of legislation). Discussed draft legislation, the State Energy Accountability Act, to create a new Public Utility Regulatory Policies Act (PURPA) section 111(d) must-consider requirement to require state regulatory authorities that implement an intermittent energy policy to considering conducting and making public an evaluation of the policys impact on reliability, including during extreme weather, and affordability, among other impacts. Discussed draft legislation, the State Planning for Reliability and Affordability Act, to require utilities to establish sufficient reliable generation facilities to ensure the availability of electric energy over a 10-year period as part of integrated resource planning. Discussed the importance of maintaining grid reliability and resource adequacy issues. Also discussed the importance of electricity affordability for all customers (no legislation). Discussed public powers concerns about transmission affordability, including transmission incentives. Discussed FERCs concerns about resource adequacy and the results of recent capacity auctions. Discussed the importance of reliability, including coordination between the gas and electricity sectors. Discussed the impact of changing tariffs on supply chains for electric utilities (no legislation). Discussed the importance of the Tennessee Valley Authority in providing affordable and reliable power to the Tennessee Valley.
Fix Our Forests Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the importance of maintaining adequate staffing levels at the Power Marketing Administrations (no legislation). Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund. Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed support for H.R. 1001, to provide for a memorandum of understanding to address the impacts of a certain record of decision on the Upper Colorado River Basin Fund. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed draft legislation to amend the Forest Land Policy and Management Act (P.L. 94-579) to amend strict liability caps for wildfires on federal lands.
Fix Our Forests Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed support for agency actions to expedite environmental reviews under NEPA, the Endangered Species Act, and National Historic Preservation Act to reduce the risk of wildfires. Discussed strict liability caps for wildfires on federal lands under the Forest Land Policy and Management Act (P.L. 94-579). Discussed the need for more consistency of land management practices at federal land management agencies, such as U.S. Forest Service and the Bureau of Land Management. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions).
AI Fraud Accountability Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed CISAs work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed concerns with the creation of additional cyber incident reporting requirements for electric utilities (no legislation). Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Also discussed extending the availability of existing funds and qualifications for awards. Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities. Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616, the Reliable Power Act, to give the Federal Energy Regulatory Commission (FERC) the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 3843, the Baseline Reliability Protection Act (all provisions), to prohibit retirements of baseload electric generating units in any area that is served by a Regional Transmission Organization or an Independent System Operator and that the North American Electric Reliability Corporation categorizes as at elevated risk or high risk of electricity supply shortfalls. Discussed resource adequacy issues and the importance of grid reliability (no legislation). Discussed H.R. 3699, the Energy Choice Act, to prohibit states or local governments from prohibiting or limiting the connection, reconnection, modification, installation, transportation, distribution, or expansion of an energy service based on the type or source of energy to be delivered (all provisions). Discussed how public power utilities, both transmission owners and transmission dependent, interact with FERC, participate in wholesale electricity markets, and other regional planning bodies (no legislation). Discussed the Department of Energys Speed to Power Initiative and the importance of resource adequacy for grid reliability. Discussed the impact tariffs are having on public power utilities (no legislation).
Southwestern Power Administration Fund Establishment Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed support for agency actions to expedite environmental reviews under NEPA, the Endangered Species Act, and National Historic Preservation Act to reduce the risk of wildfires. Discussed strict liability caps for wildfires on federal lands under the Forest Land Policy and Management Act (P.L. 94-579). Discussed the need for more consistency of land management practices at federal land management agencies, such as U.S. Forest Service and the Bureau of Land Management. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions).
Maintaining and Enhancing Hydroelectricity and River Restoration Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed opposition to potential budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 to amend, in whole or in part, 26 USC 6817, elective payment of energy tax credits. Discussed support for possible legislation to amend 26 USC 6417, elective payment of energy tax credits. Discussed opposition to possible guidance superseding IRS Notice 2013-29, defining beginning of construction for purposes of designating a qualifying facility for certain clean energy projects. Discussed support of possible guidance relating to 26 USC 45U, existing nuclear tax credit, and 26 USC 7701(51)(a), prohibited foreign entity debt test. Discussed the need for the Treasury Department to issue 45U tax guidance for existing nuclear tax credits (no legislation). Discussed possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts. Discussed support for possible regulations to implement section 26 USC 7701(a)(51), prohibited foreign entity debt test. Discussed support for possible regulations to 26 USC 6417, elective payment of energy tax credits. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed support for possible legislation to waiver 2 USC 20A, Statutory Pay-as-You-Go, in relation to the budget effects of P.L. 119-21, the One Big, Beautiful Bill Act of 2025.
Maintaining and Enhancing Hydroelectricity and River Restoration Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the public power business model. Discussed the role of the Electricity Subsector Coordinating Council (ESCC) and the need for Critical Infrastructure Partnership Advisory Council (CIPAC) protections that allow the ESCC to be operational. Discussed the importance of the Federal Emergency Management Agency (FEMA) in coordinating the response to federal disasters and the restoration of electricity after such disasters. Discussed the upcoming hurricane season and the importance of the Department of Energy (DOE) as a partner in the mutual aid response given federal waivers and exemptions authority primarily resides in the Office of Cybersecurity, Energy Security, and Emergency Response within DOE. Discussed APPAs involvement with the Energy Threat Analysis Center. Discussed support for the reauthorization of the Cybersecurity and Information Security Act of 2015 (passed as Division N of P.L. 114-113) and provisions to maintain public power utilities inclusion in the definition of private entity in section 102(15)(B) and maintaining public power utilities inclusion in section 104(B) - Exemption from Disclosure. Discussed the importance of the Rural and Municipal Advanced Cybersecurity Grant Technical Assistance Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58) to help smaller public power utilities with their cybersecurity posture. Discussed concerns with proposed rescissions of funding for the RMUC Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58). Discussed how public power utilities are utilizing the Grid Resilience and Innovation Partnerships (GRIP) Program to enhance grid reliability and affordability in their communities. Discussed APPA support for the GRIP Program and protecting obligated funds from potential rescissions (no legislation). Discussed support for S. 448, the Credit Incentives for Resilient Critical Utility Infrastructure and Transformers (CIRCUIT) Act to provide tax credits to the manufacturers of distribution transformers (all provisions). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed the importance of hydropower to the electric grid and reliability. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed draft appropriations report language for DOE to study the feasibility of federal technical assistance and regional planning to meet local and regional energy goals. Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed congressional oversight of the interconnection queue process (no legislation). Discussed the need for more flexibility for Federal Energy Regulatory Commission (FERC) and regional transmission organizations in prioritizing interconnection queues based on regional needs rather than resource attributes. Discussed H.R. 1047/S. 465, the GRID Power Act, to direct FERC to reform the interconnection queue process for the prioritization and approval of certain projects (all provisions). Discussed support for H.R. 3616, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (pre-introduction and post-introduction of legislation). Discussed draft legislation, the State Energy Accountability Act, to create a new Public Utility Regulatory Policies Act (PURPA) section 111(d) must-consider requirement to require state regulatory authorities that implement an intermittent energy policy to considering conducting and making public an evaluation of the policys impact on reliability, including during extreme weather, and affordability, among other impacts. Discussed draft legislation, the State Planning for Reliability and Affordability Act, to require utilities to establish sufficient reliable generation facilities to ensure the availability of electric energy over a 10-year period as part of integrated resource planning. Discussed the importance of maintaining grid reliability and resource adequacy issues. Also discussed the importance of electricity affordability for all customers (no legislation). Discussed public powers concerns about transmission affordability, including transmission incentives. Discussed FERCs concerns about resource adequacy and the results of recent capacity auctions. Discussed the importance of reliability, including coordination between the gas and electricity sectors. Discussed the impact of changing tariffs on supply chains for electric utilities (no legislation). Discussed the importance of the Tennessee Valley Authority in providing affordable and reliable power to the Tennessee Valley.
Maintaining and Enhancing Hydroelectricity and River Restoration Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the public power business model. Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed the implementation of Rural and Municipal Advanced Cybersecurity Grant Technical Assistance Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58). Discussed support for S. 448, the Credit Incentives for Resilient Critical Utility Infrastructure and Transformers (CIRCUIT) Act to provide tax credits to the manufacturers of distribution transformers (all provisions). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed draft language to not require licensees to obtain approval for non-substantive alterations or additions at hydropower facilities, routine maintenance, or replacement of hydropower projects that are in response to circumstances beyond their reasonable control. (no legislation). Discussed support for S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed energy tax credits for hydropower (no legislation). Discussed concerns with Form EIA-112, Residential Utility Disconnections Survey (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would exempt Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed interconnection queue reform efforts (no legislation). Discussed H.R. 1047/S. 465, the GRID Power Act to direct the Federal Energy Regulatory Commission to reform the interconnection queue process for the prioritization and approval of certain projects (all provisions). Discussed concerns with transmission affordability and rising transmission costs, and support for policies, such as joint ownership and eliminating unnecessary incentives, that would reduce transmission costs (no legislation). Discussed the importance of maintaining grid reliability and resource adequacy issues. Also discussed of electricity affordability for all customers (no legislation). Discussed the potential impact of federal funding freezes (no legislation). Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort.
Fix Our Forests Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed support for agency actions to expedite environmental reviews under NEPA, the Endangered Species Act, and National Historic Preservation Act to reduce the risk of wildfires. Discussed strict liability caps for wildfires on federal lands under the Forest Land Policy and Management Act (P.L. 94-579). Discussed the need for more consistency of land management practices at federal land management agencies, such as U.S. Forest Service and the Bureau of Land Management. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions).
Fix Our Forests Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the importance of maintaining adequate staffing levels at the Power Marketing Administrations (no legislation). Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund. Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed support for H.R. 1001, to provide for a memorandum of understanding to address the impacts of a certain record of decision on the Upper Colorado River Basin Fund. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed draft legislation to amend the Forest Land Policy and Management Act (P.L. 94-579) to amend strict liability caps for wildfires on federal lands.
LOCAL Infrastructure Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 6817, elective payment of energy tax credits. Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed opposition to potential budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed opposition to potential budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 to amend, in whole or in part, 26 USC 6817, elective payment of energy tax credits. Discussed support for striking section 70512(f), Elimination of Exception from Phaseout for Elective Payment, from the Senate Finance Committee budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 (concurrent resolution on the budget for fiscal year 2025). Discussed opposition to Senate Finance Committee budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 (concurrent resolution on the budget for fiscal year 2025) section 70513(b) (restrictions relating to prohibited foreign entities) provision requiring publicly held debt to be tested for ownership by specified foreign entities. Discussed opposition to H.R. 1, section 70513(b) (restrictions relating to prohibited foreign entities) as passed by the House, provision requiring publicly held debt to be tested for ownership by specified foreign entities. Discussed opposition to section 70512(f), Termination for Wind and Solar Facilities, ending the production tax credits for projects placed in service after 2027, and section 70513(a), Termination for Wind and Solar Facilities, ending the production tax credits for projects placed in service after 2027, in Senate amendment 2360, (the Senate Budget Committee Amendment to H.R. 1). Discussed support for striking section 70512(f), Elimination of Exception from Phaseout for Elective Payment, from Senate amendment 2360, (the Senate Budget Committee Amendment to H.R. 1). Discussed Elective Pay Blueprint APPA developed for APPA members to guide them on energy tax credits. Discussed support for S. 1481, the LOCAL Infrastructure Act, to reinstate advance refunding bonds. Discussed support for S. 5212, the Enhanced Energy Recovery Act, provisions ensuring tax credits for expanding carbon capture are available via elective payment.
Help Hoover Dam Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the importance of maintaining adequate staffing levels at the Power Marketing Administrations (no legislation). Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund. Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed support for H.R. 1001, to provide for a memorandum of understanding to address the impacts of a certain record of decision on the Upper Colorado River Basin Fund. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed draft legislation to amend the Forest Land Policy and Management Act (P.L. 94-579) to amend strict liability caps for wildfires on federal lands.
Help Hoover Dam Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed support for agency actions to expedite environmental reviews under NEPA, the Endangered Species Act, and National Historic Preservation Act to reduce the risk of wildfires. Discussed strict liability caps for wildfires on federal lands under the Forest Land Policy and Management Act (P.L. 94-579). Discussed the need for more consistency of land management practices at federal land management agencies, such as U.S. Forest Service and the Bureau of Land Management. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions).
Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed CISAs work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed concerns with the creation of additional cyber incident reporting requirements for electric utilities (no legislation). Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Also discussed extending the availability of existing funds and qualifications for awards. Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities. Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616, the Reliable Power Act, to give the Federal Energy Regulatory Commission (FERC) the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 3843, the Baseline Reliability Protection Act (all provisions), to prohibit retirements of baseload electric generating units in any area that is served by a Regional Transmission Organization or an Independent System Operator and that the North American Electric Reliability Corporation categorizes as at elevated risk or high risk of electricity supply shortfalls. Discussed resource adequacy issues and the importance of grid reliability (no legislation). Discussed H.R. 3699, the Energy Choice Act, to prohibit states or local governments from prohibiting or limiting the connection, reconnection, modification, installation, transportation, distribution, or expansion of an energy service based on the type or source of energy to be delivered (all provisions). Discussed how public power utilities, both transmission owners and transmission dependent, interact with FERC, participate in wholesale electricity markets, and other regional planning bodies (no legislation). Discussed the Department of Energys Speed to Power Initiative and the importance of resource adequacy for grid reliability. Discussed the impact tariffs are having on public power utilities (no legislation).
CIRCUIT Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the public power business model. Discussed the role of the Electricity Subsector Coordinating Council (ESCC) and the need for Critical Infrastructure Partnership Advisory Council (CIPAC) protections that allow the ESCC to be operational. Discussed the importance of the Federal Emergency Management Agency (FEMA) in coordinating the response to federal disasters and the restoration of electricity after such disasters. Discussed the upcoming hurricane season and the importance of the Department of Energy (DOE) as a partner in the mutual aid response given federal waivers and exemptions authority primarily resides in the Office of Cybersecurity, Energy Security, and Emergency Response within DOE. Discussed APPAs involvement with the Energy Threat Analysis Center. Discussed support for the reauthorization of the Cybersecurity and Information Security Act of 2015 (passed as Division N of P.L. 114-113) and provisions to maintain public power utilities inclusion in the definition of private entity in section 102(15)(B) and maintaining public power utilities inclusion in section 104(B) - Exemption from Disclosure. Discussed the importance of the Rural and Municipal Advanced Cybersecurity Grant Technical Assistance Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58) to help smaller public power utilities with their cybersecurity posture. Discussed concerns with proposed rescissions of funding for the RMUC Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58). Discussed how public power utilities are utilizing the Grid Resilience and Innovation Partnerships (GRIP) Program to enhance grid reliability and affordability in their communities. Discussed APPA support for the GRIP Program and protecting obligated funds from potential rescissions (no legislation). Discussed support for S. 448, the Credit Incentives for Resilient Critical Utility Infrastructure and Transformers (CIRCUIT) Act to provide tax credits to the manufacturers of distribution transformers (all provisions). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed the importance of hydropower to the electric grid and reliability. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed draft appropriations report language for DOE to study the feasibility of federal technical assistance and regional planning to meet local and regional energy goals. Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed congressional oversight of the interconnection queue process (no legislation). Discussed the need for more flexibility for Federal Energy Regulatory Commission (FERC) and regional transmission organizations in prioritizing interconnection queues based on regional needs rather than resource attributes. Discussed H.R. 1047/S. 465, the GRID Power Act, to direct FERC to reform the interconnection queue process for the prioritization and approval of certain projects (all provisions). Discussed support for H.R. 3616, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (pre-introduction and post-introduction of legislation). Discussed draft legislation, the State Energy Accountability Act, to create a new Public Utility Regulatory Policies Act (PURPA) section 111(d) must-consider requirement to require state regulatory authorities that implement an intermittent energy policy to considering conducting and making public an evaluation of the policys impact on reliability, including during extreme weather, and affordability, among other impacts. Discussed draft legislation, the State Planning for Reliability and Affordability Act, to require utilities to establish sufficient reliable generation facilities to ensure the availability of electric energy over a 10-year period as part of integrated resource planning. Discussed the importance of maintaining grid reliability and resource adequacy issues. Also discussed the importance of electricity affordability for all customers (no legislation). Discussed public powers concerns about transmission affordability, including transmission incentives. Discussed FERCs concerns about resource adequacy and the results of recent capacity auctions. Discussed the importance of reliability, including coordination between the gas and electricity sectors. Discussed the impact of changing tariffs on supply chains for electric utilities (no legislation). Discussed the importance of the Tennessee Valley Authority in providing affordable and reliable power to the Tennessee Valley.
CIRCUIT Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the public power business model. Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed the implementation of Rural and Municipal Advanced Cybersecurity Grant Technical Assistance Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58). Discussed support for S. 448, the Credit Incentives for Resilient Critical Utility Infrastructure and Transformers (CIRCUIT) Act to provide tax credits to the manufacturers of distribution transformers (all provisions). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed draft language to not require licensees to obtain approval for non-substantive alterations or additions at hydropower facilities, routine maintenance, or replacement of hydropower projects that are in response to circumstances beyond their reasonable control. (no legislation). Discussed support for S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed energy tax credits for hydropower (no legislation). Discussed concerns with Form EIA-112, Residential Utility Disconnections Survey (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would exempt Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed interconnection queue reform efforts (no legislation). Discussed H.R. 1047/S. 465, the GRID Power Act to direct the Federal Energy Regulatory Commission to reform the interconnection queue process for the prioritization and approval of certain projects (all provisions). Discussed concerns with transmission affordability and rising transmission costs, and support for policies, such as joint ownership and eliminating unnecessary incentives, that would reduce transmission costs (no legislation). Discussed the importance of maintaining grid reliability and resource adequacy issues. Also discussed of electricity affordability for all customers (no legislation). Discussed the potential impact of federal funding freezes (no legislation). Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort.
GRID Power Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the public power business model. Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed the implementation of Rural and Municipal Advanced Cybersecurity Grant Technical Assistance Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58). Discussed support for S. 448, the Credit Incentives for Resilient Critical Utility Infrastructure and Transformers (CIRCUIT) Act to provide tax credits to the manufacturers of distribution transformers (all provisions). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed draft language to not require licensees to obtain approval for non-substantive alterations or additions at hydropower facilities, routine maintenance, or replacement of hydropower projects that are in response to circumstances beyond their reasonable control. (no legislation). Discussed support for S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed energy tax credits for hydropower (no legislation). Discussed concerns with Form EIA-112, Residential Utility Disconnections Survey (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would exempt Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed interconnection queue reform efforts (no legislation). Discussed H.R. 1047/S. 465, the GRID Power Act to direct the Federal Energy Regulatory Commission to reform the interconnection queue process for the prioritization and approval of certain projects (all provisions). Discussed concerns with transmission affordability and rising transmission costs, and support for policies, such as joint ownership and eliminating unnecessary incentives, that would reduce transmission costs (no legislation). Discussed the importance of maintaining grid reliability and resource adequacy issues. Also discussed of electricity affordability for all customers (no legislation). Discussed the potential impact of federal funding freezes (no legislation). Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort.
GRID Power Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the public power business model. Discussed the role of the Electricity Subsector Coordinating Council (ESCC) and the need for Critical Infrastructure Partnership Advisory Council (CIPAC) protections that allow the ESCC to be operational. Discussed the importance of the Federal Emergency Management Agency (FEMA) in coordinating the response to federal disasters and the restoration of electricity after such disasters. Discussed the upcoming hurricane season and the importance of the Department of Energy (DOE) as a partner in the mutual aid response given federal waivers and exemptions authority primarily resides in the Office of Cybersecurity, Energy Security, and Emergency Response within DOE. Discussed APPAs involvement with the Energy Threat Analysis Center. Discussed support for the reauthorization of the Cybersecurity and Information Security Act of 2015 (passed as Division N of P.L. 114-113) and provisions to maintain public power utilities inclusion in the definition of private entity in section 102(15)(B) and maintaining public power utilities inclusion in section 104(B) - Exemption from Disclosure. Discussed the importance of the Rural and Municipal Advanced Cybersecurity Grant Technical Assistance Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58) to help smaller public power utilities with their cybersecurity posture. Discussed concerns with proposed rescissions of funding for the RMUC Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58). Discussed how public power utilities are utilizing the Grid Resilience and Innovation Partnerships (GRIP) Program to enhance grid reliability and affordability in their communities. Discussed APPA support for the GRIP Program and protecting obligated funds from potential rescissions (no legislation). Discussed support for S. 448, the Credit Incentives for Resilient Critical Utility Infrastructure and Transformers (CIRCUIT) Act to provide tax credits to the manufacturers of distribution transformers (all provisions). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed the importance of hydropower to the electric grid and reliability. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed draft appropriations report language for DOE to study the feasibility of federal technical assistance and regional planning to meet local and regional energy goals. Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed congressional oversight of the interconnection queue process (no legislation). Discussed the need for more flexibility for Federal Energy Regulatory Commission (FERC) and regional transmission organizations in prioritizing interconnection queues based on regional needs rather than resource attributes. Discussed H.R. 1047/S. 465, the GRID Power Act, to direct FERC to reform the interconnection queue process for the prioritization and approval of certain projects (all provisions). Discussed support for H.R. 3616, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (pre-introduction and post-introduction of legislation). Discussed draft legislation, the State Energy Accountability Act, to create a new Public Utility Regulatory Policies Act (PURPA) section 111(d) must-consider requirement to require state regulatory authorities that implement an intermittent energy policy to considering conducting and making public an evaluation of the policys impact on reliability, including during extreme weather, and affordability, among other impacts. Discussed draft legislation, the State Planning for Reliability and Affordability Act, to require utilities to establish sufficient reliable generation facilities to ensure the availability of electric energy over a 10-year period as part of integrated resource planning. Discussed the importance of maintaining grid reliability and resource adequacy issues. Also discussed the importance of electricity affordability for all customers (no legislation). Discussed public powers concerns about transmission affordability, including transmission incentives. Discussed FERCs concerns about resource adequacy and the results of recent capacity auctions. Discussed the importance of reliability, including coordination between the gas and electricity sectors. Discussed the impact of changing tariffs on supply chains for electric utilities (no legislation). Discussed the importance of the Tennessee Valley Authority in providing affordable and reliable power to the Tennessee Valley.
Port Modernization and Supply Chain Protection Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the public power business model. Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed the implementation of Rural and Municipal Advanced Cybersecurity Grant Technical Assistance Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58). Discussed support for S. 448, the Credit Incentives for Resilient Critical Utility Infrastructure and Transformers (CIRCUIT) Act to provide tax credits to the manufacturers of distribution transformers (all provisions). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed draft language to not require licensees to obtain approval for non-substantive alterations or additions at hydropower facilities, routine maintenance, or replacement of hydropower projects that are in response to circumstances beyond their reasonable control. (no legislation). Discussed support for S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed energy tax credits for hydropower (no legislation). Discussed concerns with Form EIA-112, Residential Utility Disconnections Survey (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would exempt Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed interconnection queue reform efforts (no legislation). Discussed H.R. 1047/S. 465, the GRID Power Act to direct the Federal Energy Regulatory Commission to reform the interconnection queue process for the prioritization and approval of certain projects (all provisions). Discussed concerns with transmission affordability and rising transmission costs, and support for policies, such as joint ownership and eliminating unnecessary incentives, that would reduce transmission costs (no legislation). Discussed the importance of maintaining grid reliability and resource adequacy issues. Also discussed of electricity affordability for all customers (no legislation). Discussed the potential impact of federal funding freezes (no legislation). Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort.
Port Modernization and Supply Chain Protection Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed CISAs work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed concerns with the creation of additional cyber incident reporting requirements for electric utilities (no legislation). Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Also discussed extending the availability of existing funds and qualifications for awards. Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities. Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616, the Reliable Power Act, to give the Federal Energy Regulatory Commission (FERC) the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 3843, the Baseline Reliability Protection Act (all provisions), to prohibit retirements of baseload electric generating units in any area that is served by a Regional Transmission Organization or an Independent System Operator and that the North American Electric Reliability Corporation categorizes as at elevated risk or high risk of electricity supply shortfalls. Discussed resource adequacy issues and the importance of grid reliability (no legislation). Discussed H.R. 3699, the Energy Choice Act, to prohibit states or local governments from prohibiting or limiting the connection, reconnection, modification, installation, transportation, distribution, or expansion of an energy service based on the type or source of energy to be delivered (all provisions). Discussed how public power utilities, both transmission owners and transmission dependent, interact with FERC, participate in wholesale electricity markets, and other regional planning bodies (no legislation). Discussed the Department of Energys Speed to Power Initiative and the importance of resource adequacy for grid reliability. Discussed the impact tariffs are having on public power utilities (no legislation).
Basin Fund Preservation Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed concerns with third-party efforts to remove the Lower Snake River Dams and the importance of hydropower (no bill). Discussed the importance of the federal Power Marketing Administrations that provide federal hydropower to public power utilities and opposition to any attempts to privatize them in whole or in part. Discussed impacts staff reductions could have on the operations of the federal Power Marketing Administrations. Discussed support for S. 887, the Basin Fund Preservation Act to provide for a memorandum of understanding to address the impacts of a certain record of decision on the Upper Colorado River Basin Fund (all provisions).
Guam Emergency Alert System Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed CISAs work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed concerns with the creation of additional cyber incident reporting requirements for electric utilities (no legislation). Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Also discussed extending the availability of existing funds and qualifications for awards. Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities. Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616, the Reliable Power Act, to give the Federal Energy Regulatory Commission (FERC) the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 3843, the Baseline Reliability Protection Act (all provisions), to prohibit retirements of baseload electric generating units in any area that is served by a Regional Transmission Organization or an Independent System Operator and that the North American Electric Reliability Corporation categorizes as at elevated risk or high risk of electricity supply shortfalls. Discussed resource adequacy issues and the importance of grid reliability (no legislation). Discussed H.R. 3699, the Energy Choice Act, to prohibit states or local governments from prohibiting or limiting the connection, reconnection, modification, installation, transportation, distribution, or expansion of an energy service based on the type or source of energy to be delivered (all provisions). Discussed how public power utilities, both transmission owners and transmission dependent, interact with FERC, participate in wholesale electricity markets, and other regional planning bodies (no legislation). Discussed the Department of Energys Speed to Power Initiative and the importance of resource adequacy for grid reliability. Discussed the impact tariffs are having on public power utilities (no legislation).
Guam Emergency Alert System Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed potential legislation regarding the Energy Threat Analysis Center and obstacles to increased public power participation. Discussed support for the reauthorization of the Cybersecurity and Information Security Act of 2015 (passed as Division N of P.L. 114-113) and provisions to maintain public power utilities inclusion in the definition of private entity in section 102(15)(B) and maintaining public power utilities inclusion in section 104(B) - Exemption from Disclosure. Discussed the urgent need for a replacement for the public disclosure exemptions that were provided under the Critical Infrastructure Partnership Advisory Council to facilitate information sharing at Electricity Subsector Coordinating Council meetings (no legislation). Discussed CISAs work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for S. 1337, the Cybersecurity Information Sharing Extension Act (all provisions). Discussed support for H.R. 5079, the Widespread Information Management for the Welfare of Infrastructure and Government Act (all provisions). Discussed concerns with the creation of additional cyber incident reporting requirements for electric utilities (no legislation). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed support of H.R. 3657, the Hydropower Licensing Transparency Act, to direct the Federal Energy Regulatory Commission (FERC) to report annually to Congress on the status of the relicensing process for each application for a renewed hydropower dam license. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, from the 118th Congress, which would have expanded the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would have exempted Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed grid-enhancing technologies (GETS) and interconnection queue reform. Also discussed the need to ensure savings related to GETS benefits public power utilities and their customers (no bill). Discussed support for H.R. 3616, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Provided feedback on a draft bill to create a new must consider provision under section 111(d) of the Public Utility Regulatory Policy Act that would seek to create interconnection procedures to support microgrids. Discussed public powers concerns about transmission affordability, including transmission incentives. Discussed FERCs concerns about resource adequacy and the results of recent capacity auctions, including issues in Docket AD25-7. Discussed the importance of reliability, including coordination between the gas and electricity sectors. Discussed the North American Electric Reliability Corporations (NERC) electric reliability standards development procedures and the impact of FERC Order No. 907 (directing modifications to NERCs critical infrastructure protection standards) on the prioritization of NERCs standards development work. Discussed the importance of the Tennessee Valley Authority in providing affordable and reliable power to the Tennessee Valley.
Enhanced Energy Recovery Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 6817, elective payment of energy tax credits. Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed opposition to potential budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed opposition to potential budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 to amend, in whole or in part, 26 USC 6817, elective payment of energy tax credits. Discussed support for striking section 70512(f), Elimination of Exception from Phaseout for Elective Payment, from the Senate Finance Committee budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 (concurrent resolution on the budget for fiscal year 2025). Discussed opposition to Senate Finance Committee budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 (concurrent resolution on the budget for fiscal year 2025) section 70513(b) (restrictions relating to prohibited foreign entities) provision requiring publicly held debt to be tested for ownership by specified foreign entities. Discussed opposition to H.R. 1, section 70513(b) (restrictions relating to prohibited foreign entities) as passed by the House, provision requiring publicly held debt to be tested for ownership by specified foreign entities. Discussed opposition to section 70512(f), Termination for Wind and Solar Facilities, ending the production tax credits for projects placed in service after 2027, and section 70513(a), Termination for Wind and Solar Facilities, ending the production tax credits for projects placed in service after 2027, in Senate amendment 2360, (the Senate Budget Committee Amendment to H.R. 1). Discussed support for striking section 70512(f), Elimination of Exception from Phaseout for Elective Payment, from Senate amendment 2360, (the Senate Budget Committee Amendment to H.R. 1). Discussed Elective Pay Blueprint APPA developed for APPA members to guide them on energy tax credits. Discussed support for S. 1481, the LOCAL Infrastructure Act, to reinstate advance refunding bonds. Discussed support for S. 5212, the Enhanced Energy Recovery Act, provisions ensuring tax credits for expanding carbon capture are available via elective payment.
ARC Act of 2024
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed S. 5421, the Accelerating Reliable Capacity (ARC) Act, from the 118th Congress, to incentivize new investments in new nuclear reactors. Discussed changes to section 3 to ensure that utilities that partner with the Power Marketing Administrations and Tennessee Valley Authority can receive loan guarantees.
Reserved for the Speaker.
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed H.R. 10,227, the STORE Nuclear Fuel Act of 2024 (all provisions). Discussed support for the construction of an interim nuclear waste storage facility in a willing host community and a permanent repository for used nuclear fuel and other nuclear waste, including but not limited to Yucca Mountain. Discussed S. 5421, the Accelerating Reliable Capacity (ARC) Act, to incentivize new investments in new nuclear reactors. Discussed changes to section 3 to ensure that utilities that partner with the Power Marketing Administrations and Tennessee Valley Authority can receive loan guarantees.
FEMA Loan Interest Payment Relief Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 2672, the FEMA Loan Interest Payment Relief Act.
Hydropower Clean Energy Future Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed possible funding for the Department of Energy (DOE) to assist manufacturers of distribution transformers in increasing their production (no legislation). Discussed the patchwork of cyber incident reporting requirements and concerns about harmonization, including the Cybersecurity and Infrastructure Security Agencys implementation of the Cyber Incident Reporting for Critical Infrastructure Act (CISA-2022-0010). Discussed support for H.R. 4045, the Hydropower Clean Energy Future Act (all provisions). Discussed support for S. 2994/H.R. 6653, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed concerns with Form EIA-112, Residential Utility Disconnections Survey. Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would exempt Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Provided feedback on draft legislation, the Rural Grid Resilience Act, to promote microgrids and grid resilience in rural communities. Discussed the price spike in PJMs 2024 Base Residual Auction and efforts by stakeholders to postpone PJMs 2025 Base Residual Auction. Discussed how the Federal Energy Regulatory Commissions (FERC) regulations impact public power communities despite most public power utilities not being subject to FERC ratemaking regulation. Discussed concerns with transmission affordability and rising transmission costs, and support for policies, such as joint ownership and eliminating unnecessary incentives, that would reduce transmission costs. Discussed concerns regarding the long lead times to interconnect new generation resources, and support for policies that prioritize interconnection for load-serving entities.
Hydropower Clean Energy Future Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed efforts at the Department of Energy (DOE) to address the distribution transformer supply chain crisis. Discussed DOEs final energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they were improved from proposed standards. Discussed H.R. 4167, the Protecting Americas Distribution Transformer Supply Chain Act, to prevent DOE from proposing or enacting new energy efficiency standards for distribution transformers for five years. Discussed the Cybersecurity and Infrastructure Security Agency's Notice of Proposed Rulemaking to implement the requirements of the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (Docket Number: CISA-2022-0010) and the need to avoid duplicative reporting requirements. Discussed support for the Charging and Fueling Infrastructure Grant Program under Subtitle D, sec. 11401 of the Infrastructure Investment and Jobs Act (P.L. 115-58). Discussed support for the Department of Energy Grid Resilience and Innovation Partnerships (GRIP) Program (P.L. 117-58, sections 40101, 40103, and 40107). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed the importance of hydropower as a source of renewable energy for public power utilities. Discussed the importance of hydropower for grid reliability. Discussed support for H.R. 4045, the Hydropower Clean Energy Future Act (all provisions). Discussed S. 1521, the Community & Hydropower Improvement Act (all provisions). Discussed support for S. 2994/H.R. 6653, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed H.R. 5551/S. 2827, the BIG WIRES Act, to give the Federal Energy Regulatory Commission (FERC) the authority to require the expansion of transmission facilities for reliability and establish thresholds for interregional transfer capability (all provisions). Discussed H.R. 6747, the Clean Electricity and Transmission Acceleration Act of 2023 (CETA), to direct FERC to determine the existing electricity transfer capacity between regions and to establish minimum levels of transfer capabilities between each region, and to require each transmission planning region to coordinate with its neighbors to plan for the required interregional transmission (all provisions). Discussed the need for permitting reform to help expedite the siting and permitting of energy projects to meet emissions reduction goals. Discussed support for permitting reform to help expedite the construction of energy infrastructure (no bill), including changes to the National Environmental Policy Act to streamline processes but not include transmission-related language that would expand FERCs jurisdiction over cost allocation and potentially saddle public power utilities with additional transmission costs. Discussed the importance of joint ownership opportunities for public power utilities as new transmission projects are being built. Discussed how it could help reduce transmission costs for customers and build community support for transmission projects. Discussed amendment 8 to H.R. 7023, the Creating Confidence in Clean Water Permitting Act, which would make it more difficult and costly to permit certain electric transmission projects. Discussed S. 4027/H.R. 7786, the SPEED and Reliability Act of 2024 (section (2)(a)(D)), on the exemption of a facility as in the national interest from review under the National Environmental Policy Act. Discussed concerns with overly stringent Build America/Buy America standards in the Infrastructure Investment and Jobs Act (P.L. 117-58) and the impact those standards have on public power utilities ability to complete grant-funded projects. Discussed the need to increase product and asset availability, price transparency, accountability, and coordination between the natural gas and electric industries to ensure electric reliability (no legislation). Discussed how FERCs Order 1920 (Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17)) was a missed opportunity to deal with cost allocation issues and joint ownership of transmission projects. Discussed electric transmission costs, planning, and joint ownership, including FERCs Notice of Proposed Rulemaking, Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17). Discussed resource adequacy issues. Discussed Western markets. Discussed FERCs practice and procedure and generator interconnection issues, including implementation of Order 2023 (Docket No. RM22-14). Discussed power market mitigation for institutional investors (Docket No. AD24-60). Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort. Discussed S. 4171, the Making Pipelines Accountable to Consumers Act (all provisions). Discussed S. 3820, the Low Income Household Water Assistance Program Establishment Act (sections 2(b) and 2(g). Discussed the White Houses 150 Comeback Communities and public power utilities can better leverage programs and policies included in the Inflation Reduction Act.
Protecting America’s Distribution Transformer Supply Chain Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed efforts at the Department of Energy (DOE) to address the distribution transformer supply chain crisis. Discussed DOEs final energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they were improved from proposed standards. Discussed H.R. 4167, the Protecting Americas Distribution Transformer Supply Chain Act, to prevent DOE from proposing or enacting new energy efficiency standards for distribution transformers for five years. Discussed the Cybersecurity and Infrastructure Security Agency's Notice of Proposed Rulemaking to implement the requirements of the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (Docket Number: CISA-2022-0010) and the need to avoid duplicative reporting requirements. Discussed support for the Charging and Fueling Infrastructure Grant Program under Subtitle D, sec. 11401 of the Infrastructure Investment and Jobs Act (P.L. 115-58). Discussed support for the Department of Energy Grid Resilience and Innovation Partnerships (GRIP) Program (P.L. 117-58, sections 40101, 40103, and 40107). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed the importance of hydropower as a source of renewable energy for public power utilities. Discussed the importance of hydropower for grid reliability. Discussed support for H.R. 4045, the Hydropower Clean Energy Future Act (all provisions). Discussed S. 1521, the Community & Hydropower Improvement Act (all provisions). Discussed support for S. 2994/H.R. 6653, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed H.R. 5551/S. 2827, the BIG WIRES Act, to give the Federal Energy Regulatory Commission (FERC) the authority to require the expansion of transmission facilities for reliability and establish thresholds for interregional transfer capability (all provisions). Discussed H.R. 6747, the Clean Electricity and Transmission Acceleration Act of 2023 (CETA), to direct FERC to determine the existing electricity transfer capacity between regions and to establish minimum levels of transfer capabilities between each region, and to require each transmission planning region to coordinate with its neighbors to plan for the required interregional transmission (all provisions). Discussed the need for permitting reform to help expedite the siting and permitting of energy projects to meet emissions reduction goals. Discussed support for permitting reform to help expedite the construction of energy infrastructure (no bill), including changes to the National Environmental Policy Act to streamline processes but not include transmission-related language that would expand FERCs jurisdiction over cost allocation and potentially saddle public power utilities with additional transmission costs. Discussed the importance of joint ownership opportunities for public power utilities as new transmission projects are being built. Discussed how it could help reduce transmission costs for customers and build community support for transmission projects. Discussed amendment 8 to H.R. 7023, the Creating Confidence in Clean Water Permitting Act, which would make it more difficult and costly to permit certain electric transmission projects. Discussed S. 4027/H.R. 7786, the SPEED and Reliability Act of 2024 (section (2)(a)(D)), on the exemption of a facility as in the national interest from review under the National Environmental Policy Act. Discussed concerns with overly stringent Build America/Buy America standards in the Infrastructure Investment and Jobs Act (P.L. 117-58) and the impact those standards have on public power utilities ability to complete grant-funded projects. Discussed the need to increase product and asset availability, price transparency, accountability, and coordination between the natural gas and electric industries to ensure electric reliability (no legislation). Discussed how FERCs Order 1920 (Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17)) was a missed opportunity to deal with cost allocation issues and joint ownership of transmission projects. Discussed electric transmission costs, planning, and joint ownership, including FERCs Notice of Proposed Rulemaking, Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17). Discussed resource adequacy issues. Discussed Western markets. Discussed FERCs practice and procedure and generator interconnection issues, including implementation of Order 2023 (Docket No. RM22-14). Discussed power market mitigation for institutional investors (Docket No. AD24-60). Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort. Discussed S. 4171, the Making Pipelines Accountable to Consumers Act (all provisions). Discussed S. 3820, the Low Income Household Water Assistance Program Establishment Act (sections 2(b) and 2(g). Discussed the White Houses 150 Comeback Communities and public power utilities can better leverage programs and policies included in the Inflation Reduction Act.
BIG WIRES Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed efforts at the Department of Energy (DOE) to address the distribution transformer supply chain crisis. Discussed DOEs final energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they were improved from proposed standards. Discussed H.R. 4167, the Protecting Americas Distribution Transformer Supply Chain Act, to prevent DOE from proposing or enacting new energy efficiency standards for distribution transformers for five years. Discussed the Cybersecurity and Infrastructure Security Agency's Notice of Proposed Rulemaking to implement the requirements of the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (Docket Number: CISA-2022-0010) and the need to avoid duplicative reporting requirements. Discussed support for the Charging and Fueling Infrastructure Grant Program under Subtitle D, sec. 11401 of the Infrastructure Investment and Jobs Act (P.L. 115-58). Discussed support for the Department of Energy Grid Resilience and Innovation Partnerships (GRIP) Program (P.L. 117-58, sections 40101, 40103, and 40107). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed the importance of hydropower as a source of renewable energy for public power utilities. Discussed the importance of hydropower for grid reliability. Discussed support for H.R. 4045, the Hydropower Clean Energy Future Act (all provisions). Discussed S. 1521, the Community & Hydropower Improvement Act (all provisions). Discussed support for S. 2994/H.R. 6653, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed H.R. 5551/S. 2827, the BIG WIRES Act, to give the Federal Energy Regulatory Commission (FERC) the authority to require the expansion of transmission facilities for reliability and establish thresholds for interregional transfer capability (all provisions). Discussed H.R. 6747, the Clean Electricity and Transmission Acceleration Act of 2023 (CETA), to direct FERC to determine the existing electricity transfer capacity between regions and to establish minimum levels of transfer capabilities between each region, and to require each transmission planning region to coordinate with its neighbors to plan for the required interregional transmission (all provisions). Discussed the need for permitting reform to help expedite the siting and permitting of energy projects to meet emissions reduction goals. Discussed support for permitting reform to help expedite the construction of energy infrastructure (no bill), including changes to the National Environmental Policy Act to streamline processes but not include transmission-related language that would expand FERCs jurisdiction over cost allocation and potentially saddle public power utilities with additional transmission costs. Discussed the importance of joint ownership opportunities for public power utilities as new transmission projects are being built. Discussed how it could help reduce transmission costs for customers and build community support for transmission projects. Discussed amendment 8 to H.R. 7023, the Creating Confidence in Clean Water Permitting Act, which would make it more difficult and costly to permit certain electric transmission projects. Discussed S. 4027/H.R. 7786, the SPEED and Reliability Act of 2024 (section (2)(a)(D)), on the exemption of a facility as in the national interest from review under the National Environmental Policy Act. Discussed concerns with overly stringent Build America/Buy America standards in the Infrastructure Investment and Jobs Act (P.L. 117-58) and the impact those standards have on public power utilities ability to complete grant-funded projects. Discussed the need to increase product and asset availability, price transparency, accountability, and coordination between the natural gas and electric industries to ensure electric reliability (no legislation). Discussed how FERCs Order 1920 (Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17)) was a missed opportunity to deal with cost allocation issues and joint ownership of transmission projects. Discussed electric transmission costs, planning, and joint ownership, including FERCs Notice of Proposed Rulemaking, Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17). Discussed resource adequacy issues. Discussed Western markets. Discussed FERCs practice and procedure and generator interconnection issues, including implementation of Order 2023 (Docket No. RM22-14). Discussed power market mitigation for institutional investors (Docket No. AD24-60). Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort. Discussed S. 4171, the Making Pipelines Accountable to Consumers Act (all provisions). Discussed S. 3820, the Low Income Household Water Assistance Program Establishment Act (sections 2(b) and 2(g). Discussed the White Houses 150 Comeback Communities and public power utilities can better leverage programs and policies included in the Inflation Reduction Act.
Grid Resiliency Tax Credit Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the importance of elective pay refundable energy tax credits included in the Inflation Reduction Act (Pub. Law 117-169) for public power investments in clean energy technologies to address climate change. Discussed concerns with implementation of the domestic content requirements necessary to access elective pay provisions in the Inflation Reduction Act (Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702). Discussed the likelihood of legislation to amend the tax treatment of municipal bonds. Discussed implementation of 26 USC 45U, the existing nuclear tax credit. Discussed support for direct pay of the nuclear investment tax credit (P.L. 117-169, sec. 13105). Discussed support for adding direct pay to S. 1793/H.R. 5803, the Grid Resiliency Tax Credit Act. Discussed possible changes to the three-year limit on customized commercial contracts under 16 CFR 1.141-7(f)(3) - private use rules for output facilities financed with tax-exempt bonds.
Fire Safe Electrical Corridors Act of 2023
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed concerns with third-party efforts to remove the Lower Snake River Dams and the importance of hydropower (no bill). Discussed concerns with sections 121(a) and 121(c) of H.R. 8812, the Water Resources Development Act of 2024, regarding the classification of authorized purposes at Army Corps of Engineers (Corps) projects and cost sharing, and support for including hydropower as a limitation to designating water supply as an Corps primary purpose in section 121 to address those concerns. Discussed support for including hydropower as a limitation on an emergency drought operations pilot program for Corps projects in AZ, CA, and NV in section 152 of the legislation. Discussed support for including hydropower as a limitation on an emergency drought operations pilot program for Corps projects in AZ, CA, and NV in section 345 of S. 4367, the Thomas R. Carper Water Resources Development Act of 2024. Discussed support for the inclusion of report language in H.R. 8812, the Water Resources Development Act of 2024, that reaffirms the ratemaking authority of the Power Marketing Administration administrators. Discussed support for section 337 in S. 4367, the Water Resources Development Act of 2024, directing the Army Corps of Engineers to apply section 1203 of the Thomas R. Carper Water Resources Development Act of 1986 to a dam safety project at Garrison Dam in North Dakota. Discussed the importance of the federal Power Marketing Administrations that provide federal hydropower to public power utilities and opposition to any attempts to private them in whole or in part. Discussed growing threats to electric utilities from wildfires (no legislation). Discussed support for H.R. 6012, the Fire Safe Electric Corridors Act (all provisions). Discussed support for sections 203 and 204 of H.R. 8790, the Fix Our Forests Act, to allow the clearing of hazard trees withing 150 feet of electric power lines and to create a new categorical exclusion for vegetation management for utility rights-of-way.
Maintaining and Enhancing Hydroelectricity and River Restoration Act of 2023
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed possible funding for the Department of Energy (DOE) to assist manufacturers of distribution transformers in increasing their production (no legislation). Discussed the patchwork of cyber incident reporting requirements and concerns about harmonization, including the Cybersecurity and Infrastructure Security Agencys implementation of the Cyber Incident Reporting for Critical Infrastructure Act (CISA-2022-0010). Discussed support for H.R. 4045, the Hydropower Clean Energy Future Act (all provisions). Discussed support for S. 2994/H.R. 6653, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed concerns with Form EIA-112, Residential Utility Disconnections Survey. Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would exempt Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Provided feedback on draft legislation, the Rural Grid Resilience Act, to promote microgrids and grid resilience in rural communities. Discussed the price spike in PJMs 2024 Base Residual Auction and efforts by stakeholders to postpone PJMs 2025 Base Residual Auction. Discussed how the Federal Energy Regulatory Commissions (FERC) regulations impact public power communities despite most public power utilities not being subject to FERC ratemaking regulation. Discussed concerns with transmission affordability and rising transmission costs, and support for policies, such as joint ownership and eliminating unnecessary incentives, that would reduce transmission costs. Discussed concerns regarding the long lead times to interconnect new generation resources, and support for policies that prioritize interconnection for load-serving entities.
Maintaining and Enhancing Hydroelectricity and River Restoration Act of 2023
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed efforts at the Department of Energy (DOE) to address the distribution transformer supply chain crisis. Discussed DOEs final energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they were improved from proposed standards. Discussed H.R. 4167, the Protecting Americas Distribution Transformer Supply Chain Act, to prevent DOE from proposing or enacting new energy efficiency standards for distribution transformers for five years. Discussed the Cybersecurity and Infrastructure Security Agency's Notice of Proposed Rulemaking to implement the requirements of the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (Docket Number: CISA-2022-0010) and the need to avoid duplicative reporting requirements. Discussed support for the Charging and Fueling Infrastructure Grant Program under Subtitle D, sec. 11401 of the Infrastructure Investment and Jobs Act (P.L. 115-58). Discussed support for the Department of Energy Grid Resilience and Innovation Partnerships (GRIP) Program (P.L. 117-58, sections 40101, 40103, and 40107). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed the importance of hydropower as a source of renewable energy for public power utilities. Discussed the importance of hydropower for grid reliability. Discussed support for H.R. 4045, the Hydropower Clean Energy Future Act (all provisions). Discussed S. 1521, the Community & Hydropower Improvement Act (all provisions). Discussed support for S. 2994/H.R. 6653, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed H.R. 5551/S. 2827, the BIG WIRES Act, to give the Federal Energy Regulatory Commission (FERC) the authority to require the expansion of transmission facilities for reliability and establish thresholds for interregional transfer capability (all provisions). Discussed H.R. 6747, the Clean Electricity and Transmission Acceleration Act of 2023 (CETA), to direct FERC to determine the existing electricity transfer capacity between regions and to establish minimum levels of transfer capabilities between each region, and to require each transmission planning region to coordinate with its neighbors to plan for the required interregional transmission (all provisions). Discussed the need for permitting reform to help expedite the siting and permitting of energy projects to meet emissions reduction goals. Discussed support for permitting reform to help expedite the construction of energy infrastructure (no bill), including changes to the National Environmental Policy Act to streamline processes but not include transmission-related language that would expand FERCs jurisdiction over cost allocation and potentially saddle public power utilities with additional transmission costs. Discussed the importance of joint ownership opportunities for public power utilities as new transmission projects are being built. Discussed how it could help reduce transmission costs for customers and build community support for transmission projects. Discussed amendment 8 to H.R. 7023, the Creating Confidence in Clean Water Permitting Act, which would make it more difficult and costly to permit certain electric transmission projects. Discussed S. 4027/H.R. 7786, the SPEED and Reliability Act of 2024 (section (2)(a)(D)), on the exemption of a facility as in the national interest from review under the National Environmental Policy Act. Discussed concerns with overly stringent Build America/Buy America standards in the Infrastructure Investment and Jobs Act (P.L. 117-58) and the impact those standards have on public power utilities ability to complete grant-funded projects. Discussed the need to increase product and asset availability, price transparency, accountability, and coordination between the natural gas and electric industries to ensure electric reliability (no legislation). Discussed how FERCs Order 1920 (Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17)) was a missed opportunity to deal with cost allocation issues and joint ownership of transmission projects. Discussed electric transmission costs, planning, and joint ownership, including FERCs Notice of Proposed Rulemaking, Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17). Discussed resource adequacy issues. Discussed Western markets. Discussed FERCs practice and procedure and generator interconnection issues, including implementation of Order 2023 (Docket No. RM22-14). Discussed power market mitigation for institutional investors (Docket No. AD24-60). Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort. Discussed S. 4171, the Making Pipelines Accountable to Consumers Act (all provisions). Discussed S. 3820, the Low Income Household Water Assistance Program Establishment Act (sections 2(b) and 2(g). Discussed the White Houses 150 Comeback Communities and public power utilities can better leverage programs and policies included in the Inflation Reduction Act.
Discussed possible regulations to implement section 26 USC 7701(a)(51)(D)(i)(l)(dd), prohibited foreign entity debt test (15 percent). Discussed support for regulations implementing 26 USC 7701(51)(D)(i)(I)(dd) regarding the prohibited foreign entity debt test (15 percent) to exempt publicly offered debt or stipulate that the underwriter of publicly offered debt is the issuee for purposes of the text. Discussed support of possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts and acquisition of existing output facilities to serve large load customers. Discussed support for elective payment of energy tax credits in the Inflation Reduction Act (26 USC 6817). Discussed concerns with implementation of the domestic content requirements necessary to access elective pay provisions in the Inflation Reduction Act (Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702). Discussed support for simplifying the qualification for elective payment under 26 USC 6417 (no legislation). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed support for H.R. 1255, the Investing in Our Communities Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed the importance of municipal bonds, which are used by public power utilities to build energy infrastructure. Discussed support for S. 1481, the Lifting Our Communities through Advanced Liquidity for Infrastructure Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed support for potential legislation to increase the $10 million small issue threshold in 26 USC 265(b)(3) to $30 million. Discussed opposition to proposed changes to tax-exempt financing to encourage the privatization of public infrastructure through asset recycling (no legislation). Discussed the potential effect of energy and natural gas prepayment transactions on tax-exempt financing.
Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed the need for action on categorical exclusions for vegetation management along power line corridors. Also discussed strict liability for utilities operating on public lands for wildfires. Discussed the importance of the federal Power Marketing Administrations that provide federal hydropower to public power utilities and opposition to any attempts to privatize them in whole or in part. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions). Discussed support for the acting commissioner of the Bureau of Reclamation to release funds in the Colorado River Dam Fund for the acquisition of wide head turbines at Hoover Dam as directed to in the report language accompanying H.R. 6938, the Energy & Water Development Appropriations Act, 2026. Discussed the need to exempt the Boulder Canyon Dam Project from the Federal Lands Recreation Enhancement Act (P.L. 108‑447), which would give the Bureau of Reclamation the ability to collect entry fees at Hoover Dam (no legislation).
Discussed support for increased funding for the Low Income Home Energy Assistance Program and efforts to ensure the timely disbursement of funds to states (LIHEAP)(no legislation). Discussed support for section 4 of H.R. 7147, the Homeland Security and Further Additional Continuing Appropriations Act, 2026, which incorporates by reference the Joint Explanatory Statement that prescribes Federal Emergency Management Agency actions regarding disaster designations, BRIC grants, public assistance payments, and staffing.
Filing targets: Defense, Dept of (DOD), Energy, Dept of, Environmental Protection Agency (EPA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Intl Trade Administration (ITA), Office of Management & Budget (OMB), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Forest Service
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2026 · first_quarter · Q1
Discussed support for H.R. 3898, the PERMIT Act, to improve the permitting process for infrastructure projects under the Clean Water Act, the provision regarding nationwide permitting and the determination of the appropriate acreage threshold for discharges into WOTUS, and the provision regarding section 18 statutory exclusion from the regulatory definition of WOTUS for waste treatment systems. Discussed support for H.R. 161, the New Source Review Permitting Improvement Act (all provisions). Discussed H.R. 1267, the PFAS Water Systems Liability Act, regarding how utilities are passive receivers of PFAS. Discussed the technology-based effluent limitations and standards for the Steam Electric Power Generating Point Source that the Environmental Protection Agency (EPA) promulgated in 2024 (RIN: 2040-AG41). Discussed EPAs proposed rule to approve state implementation plans for the 2015 ozone ambient air quality standards based on the agencys conclusion that 10 states dont contribute to downwind state nonattainment (EPA-HQ-OAR-2025-0192).
Discussed support for H.R. 4669, the FEMA Act (all provisions), including section 101 on rebuilding public infrastructure. Discussed support for H.R. 2672, the FEMA Loan Interest Payment Relief Act (all provisions) to provide financial assistance to a local government or electric cooperative as reimbursement for interest paid on a loan used for emergency or disaster recovery activities later paid for by FEMA assistance. Discussed support for its reintroduction in the 119th Congress. Discussed support for H.R. 164, the Promoting Opportunities to Widen Electrical Resilience (POWER) Act of 2025, to authorize electric utilities receiving certain emergency assistance for the restoration of power to also carry out cost-effective hazard mitigation activities in combination with the power restoration activities.
Discussed support for increased funding for the Low Income Home Energy Assistance Program (LIHEAP)(no legislation).
Discussed the Cybersecurity and Information Security Agencys (CISA) work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for S. 2983, the Protecting America from Cyber Threats Act (all provisions), to reauthorize the Cybersecurity Information Security Act of 2015 (CISA 2015). Discussed support for a replacement to the Critical Infrastructure Partnership Advisory Council at the Department of Homeland Security to facilitate interaction between governmental entities and representatives from the community of critical infrastructure owners and operators. (no legislation). Discussed support for H.R. 7258, the Energy Emergency Leadership Act, to elevate the Department of Energys energy emergency and cybersecurity responsibilities by requiring those critical functions to be led by a Senate-confirmed Assistant Secretary (all provisions). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 2072, the Build More Hydro Act, to require the Federal Energy Regulatory Commission to extend the period during which licensees are required to commence construction of certain hydropower projects (all provisions). Discussed H.R. 7940, the Safeguarding Aquatic Fisheries and Ecosystem (SAFE) Pathways Act, to amend the Federal Power Act to require the consideration of invasive species when prescribing fishways. Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed the role of grid enhancing technologies in transmission and virtual power plants (no legislation). Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed H.R. 7977, the transmission provisions in the Energy Bills Relief Act. Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 3947, the REWIRE Act, section 3, to provide categorical exclusions for transmission projects that increase grid capacity in existing rights-of-way by reconductoring, using grid enhancing technologies, and deploying energy storage, and section 4, to increase return on equity for reconductoring using advanced conductors. Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Discussed H.R. 7329, the Fighting for Reliable Energy and Ending Doubt for Open Markets (FREEDOM) Act, to amend the Energy Act of 2020, the Geothermal Steam Act of 1970, the Energy Policy Act of 2005, and the Mineral Leasing Act to streamline the leasing and permitting processes of federal agencies for certain energy and mineral projects, to clarify federal authorization requirements for certain projects on non-federal land, to establish enforceable federal authorization timelines and expedited judicial remedies, to limit federal actions halting fully permitted projects, to create a de-risking compensation program. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed draft legislation, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed Light Up Navajo project to get electricity to unserved families of the Navajo Nation (no legislation). Discussed ongoing grid hardening activities by public power utilities and needed additional investments (no legislation). Discussed potential federal funding for critical infrastructure hardening. Discussed the impact tariffs are having on public power utilities (no legislation). Discussed the impact of supply chain issues on public power utilities (no legislation). Discussed the impact from data centers on electricity prices to customers in communities that dont have data centers (FERC Docket RM26-4). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives. Discussed wholesale electricity market development efforts in the West. Discussed the public power business model and FERCs jurisdiction over public power utilities under the Federal Power Act.
Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed support for agency actions to expedite environmental reviews under the National Environmental Policy Act, Endangered Species Act, and National Historic Preservation Act to reduce the risk of wildfires. Discussed strict liability caps for wildfires on federal lands under the Forest Land Policy and Management Act (P.L. 94-579). Discussed the need for more consistency of land management practices at federal land management agencies, such as U.S. Forest Service and the Bureau of Land Management. Discussed support for comprehensive vegetation management practices along power line corridors on federal lands. Discussed Bonneville Power Administrations role in transmission in the Pacific Northwest (no legislation). Discussed the federal hydropower system in the Pacific Northwest (no legislation). Discussed support for adequate staffing levels at the federal Power Marketing Administrations (no legislation).
Discussed possible regulations to implement section 26 USC 7701(a)(51)(D)(i)(l)(dd), prohibited foreign entity debt test (15 percent). Discussed support of possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts. Discussed support for elective payment of energy tax credits in the Inflation Reduction Act (26 USC 6817) and the need for clarity from the Treasury Department on the implementation of section 26 USC 7701(a)(51), prohibited foreign entity debt test. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed support for H.R. 1255, the Investing in Our Communities Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed support for potential legislation to increase the $10 million small issue threshold in 26 USC 265(b)(3) to $30 million.
Discussed support for H.R. 4776, the SPEED Act, to reform permitting processes under the National Environmental Policy Act (all provisions). Discussed support for H.R. 4503, the ePermit Act, to digitize the federal permitting process for environmental reviews. Discussed support of reforms to the Endangered Species Act that would change the definition of habitat (no legislation). Discussed how the Endangered Species Act impacts energy infrastructure projects (no legislation). Discussed H.R. 1897, the Endangered Species Act Amendments of 2025 (all provisions). Discussed the Environmental Protection Agencys reconsideration of the 2024 Coal Combustion Residuals Legacy rule regarding the disposal of coal combustion residuals and impoundments (RIN: 2050-AH39).
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, U.S. Forest Service, White House Office
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2025 · fourth_quarter · Q4
Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed CISAs work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed concerns with the creation of additional cyber incident reporting requirements for electric utilities (no legislation). Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Also discussed extending the availability of existing funds and qualifications for awards. Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities. Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616, the Reliable Power Act, to give the Federal Energy Regulatory Commission (FERC) the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 3843, the Baseline Reliability Protection Act (all provisions), to prohibit retirements of baseload electric generating units in any area that is served by a Regional Transmission Organization or an Independent System Operator and that the North American Electric Reliability Corporation categorizes as at elevated risk or high risk of electricity supply shortfalls. Discussed resource adequacy issues and the importance of grid reliability (no legislation). Discussed H.R. 3699, the Energy Choice Act, to prohibit states or local governments from prohibiting or limiting the connection, reconnection, modification, installation, transportation, distribution, or expansion of an energy service based on the type or source of energy to be delivered (all provisions). Discussed how public power utilities, both transmission owners and transmission dependent, interact with FERC, participate in wholesale electricity markets, and other regional planning bodies (no legislation). Discussed the Department of Energys Speed to Power Initiative and the importance of resource adequacy for grid reliability. Discussed the impact tariffs are having on public power utilities (no legislation).
Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed support for agency actions to expedite environmental reviews under NEPA, the Endangered Species Act, and National Historic Preservation Act to reduce the risk of wildfires. Discussed strict liability caps for wildfires on federal lands under the Forest Land Policy and Management Act (P.L. 94-579). Discussed the need for more consistency of land management practices at federal land management agencies, such as U.S. Forest Service and the Bureau of Land Management. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions).
Discussed support of possible legislation to waive 2 U.S. Code Chapter 20A, Statutory Pay-as-You-Go, in relation to the budget effects of the One Big Beautiful Bill Act of 2025 (P.L. 119-21). Discussed support for increased funding for the Low Income Home Energy Assistance Program (LIHEAP)(no legislation). Discussed support for a mechanism that provides emergency funding for LIHEAP during government shutdowns (no legislation).
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, U.S. Fish & Wildlife Service (USFWS), U.S. Forest Service
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2025 · third_quarter · Q3
Discussed potential legislation regarding the Energy Threat Analysis Center and obstacles to increased public power participation. Discussed support for the reauthorization of the Cybersecurity and Information Security Act of 2015 (passed as Division N of P.L. 114-113) and provisions to maintain public power utilities inclusion in the definition of private entity in section 102(15)(B) and maintaining public power utilities inclusion in section 104(B) - Exemption from Disclosure. Discussed the urgent need for a replacement for the public disclosure exemptions that were provided under the Critical Infrastructure Partnership Advisory Council to facilitate information sharing at Electricity Subsector Coordinating Council meetings (no legislation). Discussed CISAs work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for S. 1337, the Cybersecurity Information Sharing Extension Act (all provisions). Discussed support for H.R. 5079, the Widespread Information Management for the Welfare of Infrastructure and Government Act (all provisions). Discussed concerns with the creation of additional cyber incident reporting requirements for electric utilities (no legislation). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed support of H.R. 3657, the Hydropower Licensing Transparency Act, to direct the Federal Energy Regulatory Commission (FERC) to report annually to Congress on the status of the relicensing process for each application for a renewed hydropower dam license. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, from the 118th Congress, which would have expanded the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would have exempted Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed grid-enhancing technologies (GETS) and interconnection queue reform. Also discussed the need to ensure savings related to GETS benefits public power utilities and their customers (no bill). Discussed support for H.R. 3616, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Provided feedback on a draft bill to create a new must consider provision under section 111(d) of the Public Utility Regulatory Policy Act that would seek to create interconnection procedures to support microgrids. Discussed public powers concerns about transmission affordability, including transmission incentives. Discussed FERCs concerns about resource adequacy and the results of recent capacity auctions, including issues in Docket AD25-7. Discussed the importance of reliability, including coordination between the gas and electricity sectors. Discussed the North American Electric Reliability Corporations (NERC) electric reliability standards development procedures and the impact of FERC Order No. 907 (directing modifications to NERCs critical infrastructure protection standards) on the prioritization of NERCs standards development work. Discussed the importance of the Tennessee Valley Authority in providing affordable and reliable power to the Tennessee Valley.
Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed opposition to potential budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 to amend, in whole or in part, 26 USC 6817, elective payment of energy tax credits. Discussed support for possible legislation to amend 26 USC 6417, elective payment of energy tax credits. Discussed opposition to possible guidance superseding IRS Notice 2013-29, defining beginning of construction for purposes of designating a qualifying facility for certain clean energy projects. Discussed support of possible guidance relating to 26 USC 45U, existing nuclear tax credit, and 26 USC 7701(51)(a), prohibited foreign entity debt test. Discussed the need for the Treasury Department to issue 45U tax guidance for existing nuclear tax credits (no legislation). Discussed possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts. Discussed support for possible regulations to implement section 26 USC 7701(a)(51), prohibited foreign entity debt test. Discussed support for possible regulations to 26 USC 6417, elective payment of energy tax credits. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed support for possible legislation to waiver 2 USC 20A, Statutory Pay-as-You-Go, in relation to the budget effects of P.L. 119-21, the One Big, Beautiful Bill Act of 2025.
Discussed the importance of maintaining adequate staffing levels at the Power Marketing Administrations (no legislation). Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund. Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed support for H.R. 1001, to provide for a memorandum of understanding to address the impacts of a certain record of decision on the Upper Colorado River Basin Fund. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed draft legislation to amend the Forest Land Policy and Management Act (P.L. 94-579) to amend strict liability caps for wildfires on federal lands.
Discussed support for increased funding for the Low Income Home Energy Assistance Program (no legislation).
Filing targets: Environmental Protection Agency (EPA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Office of Management & Budget (OMB), SENATE, Treasury, Dept of
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2025 · second_quarter · Q2
Discussed the public power business model. Discussed the role of the Electricity Subsector Coordinating Council (ESCC) and the need for Critical Infrastructure Partnership Advisory Council (CIPAC) protections that allow the ESCC to be operational. Discussed the importance of the Federal Emergency Management Agency (FEMA) in coordinating the response to federal disasters and the restoration of electricity after such disasters. Discussed the upcoming hurricane season and the importance of the Department of Energy (DOE) as a partner in the mutual aid response given federal waivers and exemptions authority primarily resides in the Office of Cybersecurity, Energy Security, and Emergency Response within DOE. Discussed APPAs involvement with the Energy Threat Analysis Center. Discussed support for the reauthorization of the Cybersecurity and Information Security Act of 2015 (passed as Division N of P.L. 114-113) and provisions to maintain public power utilities inclusion in the definition of private entity in section 102(15)(B) and maintaining public power utilities inclusion in section 104(B) - Exemption from Disclosure. Discussed the importance of the Rural and Municipal Advanced Cybersecurity Grant Technical Assistance Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58) to help smaller public power utilities with their cybersecurity posture. Discussed concerns with proposed rescissions of funding for the RMUC Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58). Discussed how public power utilities are utilizing the Grid Resilience and Innovation Partnerships (GRIP) Program to enhance grid reliability and affordability in their communities. Discussed APPA support for the GRIP Program and protecting obligated funds from potential rescissions (no legislation). Discussed support for S. 448, the Credit Incentives for Resilient Critical Utility Infrastructure and Transformers (CIRCUIT) Act to provide tax credits to the manufacturers of distribution transformers (all provisions). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed the importance of hydropower to the electric grid and reliability. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed draft appropriations report language for DOE to study the feasibility of federal technical assistance and regional planning to meet local and regional energy goals. Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed congressional oversight of the interconnection queue process (no legislation). Discussed the need for more flexibility for Federal Energy Regulatory Commission (FERC) and regional transmission organizations in prioritizing interconnection queues based on regional needs rather than resource attributes. Discussed H.R. 1047/S. 465, the GRID Power Act, to direct FERC to reform the interconnection queue process for the prioritization and approval of certain projects (all provisions). Discussed support for H.R. 3616, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (pre-introduction and post-introduction of legislation). Discussed draft legislation, the State Energy Accountability Act, to create a new Public Utility Regulatory Policies Act (PURPA) section 111(d) must-consider requirement to require state regulatory authorities that implement an intermittent energy policy to considering conducting and making public an evaluation of the policys impact on reliability, including during extreme weather, and affordability, among other impacts. Discussed draft legislation, the State Planning for Reliability and Affordability Act, to require utilities to establish sufficient reliable generation facilities to ensure the availability of electric energy over a 10-year period as part of integrated resource planning. Discussed the importance of maintaining grid reliability and resource adequacy issues. Also discussed the importance of electricity affordability for all customers (no legislation). Discussed public powers concerns about transmission affordability, including transmission incentives. Discussed FERCs concerns about resource adequacy and the results of recent capacity auctions. Discussed the importance of reliability, including coordination between the gas and electricity sectors. Discussed the impact of changing tariffs on supply chains for electric utilities (no legislation). Discussed the importance of the Tennessee Valley Authority in providing affordable and reliable power to the Tennessee Valley.
Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 6817, elective payment of energy tax credits. Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed opposition to potential budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed opposition to potential budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 to amend, in whole or in part, 26 USC 6817, elective payment of energy tax credits. Discussed support for striking section 70512(f), Elimination of Exception from Phaseout for Elective Payment, from the Senate Finance Committee budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 (concurrent resolution on the budget for fiscal year 2025). Discussed opposition to Senate Finance Committee budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 (concurrent resolution on the budget for fiscal year 2025) section 70513(b) (restrictions relating to prohibited foreign entities) provision requiring publicly held debt to be tested for ownership by specified foreign entities. Discussed opposition to H.R. 1, section 70513(b) (restrictions relating to prohibited foreign entities) as passed by the House, provision requiring publicly held debt to be tested for ownership by specified foreign entities. Discussed opposition to section 70512(f), Termination for Wind and Solar Facilities, ending the production tax credits for projects placed in service after 2027, and section 70513(a), Termination for Wind and Solar Facilities, ending the production tax credits for projects placed in service after 2027, in Senate amendment 2360, (the Senate Budget Committee Amendment to H.R. 1). Discussed support for striking section 70512(f), Elimination of Exception from Phaseout for Elective Payment, from Senate amendment 2360, (the Senate Budget Committee Amendment to H.R. 1). Discussed Elective Pay Blueprint APPA developed for APPA members to guide them on energy tax credits. Discussed support for S. 1481, the LOCAL Infrastructure Act, to reinstate advance refunding bonds. Discussed support for S. 5212, the Enhanced Energy Recovery Act, provisions ensuring tax credits for expanding carbon capture are available via elective payment.
Discussed S. 5421, the Accelerating Reliable Capacity (ARC) Act, from the 118th Congress, to incentivize new investments in new nuclear reactors. Discussed changes to section 3 to ensure that utilities that partner with the Power Marketing Administrations and Tennessee Valley Authority can receive loan guarantees.
Filing targets: Army, Dept of (Corps of Engineers), Defense, Dept of (DOD), Energy, Dept of, Environmental Protection Agency (EPA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, SENATE
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2025 · first_quarter · Q1
Discussed the public power business model. Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed the implementation of Rural and Municipal Advanced Cybersecurity Grant Technical Assistance Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58). Discussed support for S. 448, the Credit Incentives for Resilient Critical Utility Infrastructure and Transformers (CIRCUIT) Act to provide tax credits to the manufacturers of distribution transformers (all provisions). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed draft language to not require licensees to obtain approval for non-substantive alterations or additions at hydropower facilities, routine maintenance, or replacement of hydropower projects that are in response to circumstances beyond their reasonable control. (no legislation). Discussed support for S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed energy tax credits for hydropower (no legislation). Discussed concerns with Form EIA-112, Residential Utility Disconnections Survey (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would exempt Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed interconnection queue reform efforts (no legislation). Discussed H.R. 1047/S. 465, the GRID Power Act to direct the Federal Energy Regulatory Commission to reform the interconnection queue process for the prioritization and approval of certain projects (all provisions). Discussed concerns with transmission affordability and rising transmission costs, and support for policies, such as joint ownership and eliminating unnecessary incentives, that would reduce transmission costs (no legislation). Discussed the importance of maintaining grid reliability and resource adequacy issues. Also discussed of electricity affordability for all customers (no legislation). Discussed the potential impact of federal funding freezes (no legislation). Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2024 · fourth_quarter · Q4
Discussed the importance of elective pay refundable energy tax credits included in the Inflation Reduction Act (Pub. Law 117-169) for public power investments in clean energy technologies to address climate change. Discussed concerns with implementation of the domestic content requirements necessary to access elective pay provisions in the Inflation Reduction Act (Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702). Discussed support for the extension and clarification of IRS Notice 2024-9 section 5 process for attestation of good faith determination of qualification for statutory exception to the domestic content requirements for the elective payment of energy tax credits. Discussed tax credits for hydropower (no legislation).
Discussed concerns with third-party efforts to remove the Lower Snake River Dams and the importance of hydropower (no bill). Discussed support for the inclusion of report language in H.R. 8812, the Water Resources Development Act of 2024, that reaffirms the ratemaking authority of the Power Marketing Administration administrators. Discussed the importance of the federal Power Marketing Administrations that provide federal hydropower to public power utilities and opposition to any attempts to privatize them in whole or in part.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2024 · third_quarter · Q3
Discussed concerns with third-party efforts to remove the Lower Snake River Dams and the importance of hydropower (no bill). Discussed concerns with sections 121(a) and 121(c) of H.R. 8812, the Water Resources Development Act of 2024, regarding the classification of authorized purposes at Army Corps of Engineers (Corps) projects and cost sharing, and support for including hydropower as a limitation to designating water supply as an Corps primary purpose in section 121 to address those concerns. Discussed support for including hydropower as a limitation on an emergency drought operations pilot program for Corps projects in AZ, CA, and NV in section 152 of the legislation. Discussed support for including hydropower as a limitation on an emergency drought operations pilot program for Corps projects in AZ, CA, and NV in section 345 of S. 4367, the Thomas R. Carper Water Resources Development Act of 2024. Discussed support for the inclusion of report language in H.R. 8812, the Water Resources Development Act of 2024, that reaffirms the ratemaking authority of the Power Marketing Administration administrators. Discussed support for section 337 in S. 4367, the Water Resources Development Act of 2024, directing the Army Corps of Engineers to apply section 1203 of the Thomas R. Carper Water Resources Development Act of 1986 to a dam safety project at Garrison Dam in North Dakota. Discussed the importance of the federal Power Marketing Administrations that provide federal hydropower to public power utilities and opposition to any attempts to private them in whole or in part. Discussed growing threats to electric utilities from wildfires (no legislation). Discussed support for H.R. 6012, the Fire Safe Electric Corridors Act (all provisions). Discussed support for sections 203 and 204 of H.R. 8790, the Fix Our Forests Act, to allow the clearing of hazard trees withing 150 feet of electric power lines and to create a new categorical exclusion for vegetation management for utility rights-of-way.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2024 · second_quarter · Q2
Discussed concerns about the effect on public power utilities as counterparties in derivative transactions with banks as a result of increased capital requirements for large bank transactions with non-publicly traded entities under proposed rule, Regulatory Capital Rule: Large Banking Organizations and Banking Organizations with Significant Trading Activity (Docket ID: OCC-2023-0008, 88 Fed. Reg. 64028 (2023) and proposed rule, Regulatory Capital Rule: Risk-Based Capital Surcharges for Global Systemically Important Bank Holding Companies; System Risk Report (FR Y-15) (Docket No. R-1814, 88 Fed. Reg. 60385).
Discussed support for H.R. 2672, the FEMA Loan Interest Payment Relief Act.
Discussed support for increased funding for the Low Income Home Energy Assistance Program in fiscal year 2026 (no legislation).
Discussed the importance of elective pay refundable energy tax credits included in the Inflation Reduction Act (Pub. Law 117-169) for public power investments in clean energy technologies and expressed concerns with any legislative efforts to eliminate them. Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed concerns with implementation of the domestic content requirements necessary to access elective pay provisions in the Inflation Reduction Act (Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702). Discussed tax credits for hydropower (no legislation). Discussed support for H.R. 1255, the Investing in Our Communities Act, to reinstate the ability to issue tax-exempt advanced refunding bonds.
Discussed concerns with third-party efforts to remove the Lower Snake River Dams and the importance of hydropower (no bill). Discussed the importance of the federal Power Marketing Administrations that provide federal hydropower to public power utilities and opposition to any attempts to privatize them in whole or in part. Discussed impacts staff reductions could have on the operations of the federal Power Marketing Administrations. Discussed support for S. 887, the Basin Fund Preservation Act to provide for a memorandum of understanding to address the impacts of a certain record of decision on the Upper Colorado River Basin Fund (all provisions).
Discussed support for legislation in the 118th Congress to renew existing federal counter-drone authorities for large sites, including critical infrastructure (H.R. 8610, the Counter-UAS Authority Security, Safety, and Reauthorization Act) to be reintroduced in the 119th Congress. Discussed support for reintroduction of legislation from the 118th Congress to enhance the authority granted to the Department of Homeland Security and Department of Justice with respect to unmanned aircraft systems and unmanned aircraft (S. 1631, the Safeguarding the Homeland from Threats Posed by Unmanned Aircraft Systems Act).
Filing targets: Energy, Dept of, HOUSE OF REPRESENTATIVES, SENATE
Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed possible funding for the Department of Energy (DOE) to assist manufacturers of distribution transformers in increasing their production (no legislation). Discussed the patchwork of cyber incident reporting requirements and concerns about harmonization, including the Cybersecurity and Infrastructure Security Agencys implementation of the Cyber Incident Reporting for Critical Infrastructure Act (CISA-2022-0010). Discussed support for H.R. 4045, the Hydropower Clean Energy Future Act (all provisions). Discussed support for S. 2994/H.R. 6653, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed concerns with Form EIA-112, Residential Utility Disconnections Survey. Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would exempt Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Provided feedback on draft legislation, the Rural Grid Resilience Act, to promote microgrids and grid resilience in rural communities. Discussed the price spike in PJMs 2024 Base Residual Auction and efforts by stakeholders to postpone PJMs 2025 Base Residual Auction. Discussed how the Federal Energy Regulatory Commissions (FERC) regulations impact public power communities despite most public power utilities not being subject to FERC ratemaking regulation. Discussed concerns with transmission affordability and rising transmission costs, and support for policies, such as joint ownership and eliminating unnecessary incentives, that would reduce transmission costs. Discussed concerns regarding the long lead times to interconnect new generation resources, and support for policies that prioritize interconnection for load-serving entities.
Discussed H.R. 10,227, the STORE Nuclear Fuel Act of 2024 (all provisions). Discussed support for the construction of an interim nuclear waste storage facility in a willing host community and a permanent repository for used nuclear fuel and other nuclear waste, including but not limited to Yucca Mountain. Discussed S. 5421, the Accelerating Reliable Capacity (ARC) Act, to incentivize new investments in new nuclear reactors. Discussed changes to section 3 to ensure that utilities that partner with the Power Marketing Administrations and Tennessee Valley Authority can receive loan guarantees.
Filing targets: Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed H.R. 9083, the SECURE GRID Act, to amend the Energy Policy and Conservation Act to require states to include supporting the physical security, cybersecurity, and resilience of local distribution systems in State energy security plans (all provisions). Provided feedback on draft legislation to promote the deployment of virtual power plants. Provided feedback on draft legislation to help promote the development of renewable energy microgrids in rural communities. Discussed the need for the Department of Energy (DOE) to reduce the administrative burden for grants and other federal funding opportunities through DOE, especially for smaller, less-resourced utilities. Discussed how DOE could improve collaboration with electric utilities. Discussed support for S. 2994/H.R. 6653, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed support for S. 2356 from the 117th Congress, the Twenty-First Century Dams Act. Discussed concerns with Form EIA-112, Residential Utility Disconnections Survey. Discussed the need for permitting reform to help expedite the siting and permitting of energy projects to meet rising electricity demand. Discussed general support for permitting reform to help expedite the construction of energy infrastructure, including changes to the National Environmental Policy Act to streamline processes but not include transmission-related language that would expand FERCs jurisdiction over cost allocation and potentially saddle public power utilities with additional transmission costs. Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would exempt Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Discussed support for S. 4171, the Making Pipelines Accountable to Consumers and Taxpayers Act. Discussed concerns with H.R. 8032, the Low Income Household Water Assistance Program Establishment Act (all provisions).
Filing targets: Energy, Dept of, HOUSE OF REPRESENTATIVES, SENATE
Discussed support for S. 870, the ADVANCE Act (all provisions) to promote advanced nuclear technologies. Discussed the need for a solution for nuclear waste storage (no bill).
Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed efforts at the Department of Energy (DOE) to address the distribution transformer supply chain crisis. Discussed DOEs final energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they were improved from proposed standards. Discussed H.R. 4167, the Protecting Americas Distribution Transformer Supply Chain Act, to prevent DOE from proposing or enacting new energy efficiency standards for distribution transformers for five years. Discussed the Cybersecurity and Infrastructure Security Agency's Notice of Proposed Rulemaking to implement the requirements of the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (Docket Number: CISA-2022-0010) and the need to avoid duplicative reporting requirements. Discussed support for the Charging and Fueling Infrastructure Grant Program under Subtitle D, sec. 11401 of the Infrastructure Investment and Jobs Act (P.L. 115-58). Discussed support for the Department of Energy Grid Resilience and Innovation Partnerships (GRIP) Program (P.L. 117-58, sections 40101, 40103, and 40107). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed the importance of hydropower as a source of renewable energy for public power utilities. Discussed the importance of hydropower for grid reliability. Discussed support for H.R. 4045, the Hydropower Clean Energy Future Act (all provisions). Discussed S. 1521, the Community & Hydropower Improvement Act (all provisions). Discussed support for S. 2994/H.R. 6653, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed H.R. 5551/S. 2827, the BIG WIRES Act, to give the Federal Energy Regulatory Commission (FERC) the authority to require the expansion of transmission facilities for reliability and establish thresholds for interregional transfer capability (all provisions). Discussed H.R. 6747, the Clean Electricity and Transmission Acceleration Act of 2023 (CETA), to direct FERC to determine the existing electricity transfer capacity between regions and to establish minimum levels of transfer capabilities between each region, and to require each transmission planning region to coordinate with its neighbors to plan for the required interregional transmission (all provisions). Discussed the need for permitting reform to help expedite the siting and permitting of energy projects to meet emissions reduction goals. Discussed support for permitting reform to help expedite the construction of energy infrastructure (no bill), including changes to the National Environmental Policy Act to streamline processes but not include transmission-related language that would expand FERCs jurisdiction over cost allocation and potentially saddle public power utilities with additional transmission costs. Discussed the importance of joint ownership opportunities for public power utilities as new transmission projects are being built. Discussed how it could help reduce transmission costs for customers and build community support for transmission projects. Discussed amendment 8 to H.R. 7023, the Creating Confidence in Clean Water Permitting Act, which would make it more difficult and costly to permit certain electric transmission projects. Discussed S. 4027/H.R. 7786, the SPEED and Reliability Act of 2024 (section (2)(a)(D)), on the exemption of a facility as in the national interest from review under the National Environmental Policy Act. Discussed concerns with overly stringent Build America/Buy America standards in the Infrastructure Investment and Jobs Act (P.L. 117-58) and the impact those standards have on public power utilities ability to complete grant-funded projects. Discussed the need to increase product and asset availability, price transparency, accountability, and coordination between the natural gas and electric industries to ensure electric reliability (no legislation). Discussed how FERCs Order 1920 (Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17)) was a missed opportunity to deal with cost allocation issues and joint ownership of transmission projects. Discussed electric transmission costs, planning, and joint ownership, including FERCs Notice of Proposed Rulemaking, Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17). Discussed resource adequacy issues. Discussed Western markets. Discussed FERCs practice and procedure and generator interconnection issues, including implementation of Order 2023 (Docket No. RM22-14). Discussed power market mitigation for institutional investors (Docket No. AD24-60). Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort. Discussed S. 4171, the Making Pipelines Accountable to Consumers Act (all provisions). Discussed S. 3820, the Low Income Household Water Assistance Program Establishment Act (sections 2(b) and 2(g). Discussed the White Houses 150 Comeback Communities and public power utilities can better leverage programs and policies included in the Inflation Reduction Act.
Discussed support for funding for the Low Income Home Energy Assistance Program in Fiscal Year 2025 Labor, Health, and Human Services Appropriations Act (not yet drafted legislation). Discussed support for funding through the appropriations for DOE to help address labor and materials shortages for distribution transformers (no bill). Discussed funding being included in the fiscal year 2025 Energy and Water Development Appropriations bill for the Defense Production authorities to help address the distribution transformer supply chain crisis (no bill). Discussed the effects of sequestration under the Budget Control Act and Statutory Pay as You Go Act on public power utilities. Discussed the possible waiver of the sequestration provisions of the Statutory Pay as You Go Act (2 USC 931) as relates to the American Rescue Plan Act (P.L. 117-7). Discussed funding for federal grants to states for the federal Coal Combustions Residuals Permit Program and for language to direct EPA to expedite the review and approval state permit programs.
Discussed the importance of elective pay refundable energy tax credits included in the Inflation Reduction Act (Pub. Law 117-169) for public power investments in clean energy technologies to address climate change. Discussed concerns with implementation of the domestic content requirements necessary to access elective pay provisions in the Inflation Reduction Act (Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702). Discussed the likelihood of legislation to amend the tax treatment of municipal bonds. Discussed implementation of 26 USC 45U, the existing nuclear tax credit. Discussed support for direct pay of the nuclear investment tax credit (P.L. 117-169, sec. 13105). Discussed support for adding direct pay to S. 1793/H.R. 5803, the Grid Resiliency Tax Credit Act. Discussed possible changes to the three-year limit on customized commercial contracts under 16 CFR 1.141-7(f)(3) - private use rules for output facilities financed with tax-exempt bonds.
Discussed the Environmental Protection Agency's proposed rules to regulate greenhouse gas emissions from power plants (EPA-HQ-OAR-2023-0072) and the potential impacts to public power utilities, as well as potential impact on affordability and reliability. Discussed concerns with EPAs final rules to regulate greenhouse gas emissions from power plants (EPA-HQ-OAR-2023-0072) and the impact they will have on public power utilities, as well as on affordability and reliability. Discussed the creation of a federal clean energy standard and the need for Congress to provide public power utilities with regulatory certainty. Discussed S.J. Res. 92/H.R. Res. 177, a joint resolution providing for congressional disapproval of EPAs final greenhouse gas regulations for power plants. Discussed EPAs efforts to obtain quality and useful emissions information in its Air Emissions Reporting (EPA-HQ-OAR-2004-0489).
Discussed concerns with third-party efforts to remove the Lower Snake River Dams and the importance of hydropower (no bill). Discussed Columbia River Settlement Agreement and concerns with the potential impact of breaching the Lower Snake River dams on hydropower production, meeting clean energy goals, and grid reliability (no legislation). Discussed Columbia River Treaty negotiations. Discussed support for S. 3581/H.R. 6924, the Hydropower Delivery Rate-reduction Offset (HYDRO) Act. Discussed the issue of the assignment of inequitable costs by the Army Corps of Engineers to the Power Marketing Administrations and their customers. Discussed support for ensuring the Water Resources Development Act (no bill number) protects federal hydropower customers from costs issued by the Army Corps of Engineers for which they receive no benefit. Discussed language to make clear that the Power Marketing Administration Administrators retain full authority on setting rates in draft Water Resources Development Act legislation. Discussed the importance of preserving Power Marketing Administration rate making authority; the application of dam safety costs to state-of-the-art modifications; the Stockton Lake compromise on water supply and hydropower generation; and the study of power deauthorization at Willamette Valley projects in the context of future Water Resource Development Act legislation (no bill). Discussed concerns with sections 121(a) and 121(c) of H.R. 8812, the Water Resources Development Act, regarding the classification of authorized purposes at Corps projects and cost sharing. Also discussed an amendment to the legislation to create a pilot program for Corps projects in AZ, CA, and NV at which the secretary of the Army to declare water supply is an authorized purpose during drought emergencies. Discussed the importance of the federal Power Marketing Administrations that provide federal hydropower to public power utilities. Discussed growing threats to electric utilities from wildfires (no legislation). Discussed S. 4628, the Enhancing Mitigation and Building Effective Resilience Act (all provisions). Discussed H.R. 8160, the Breaking Irresponsible Energy and Commercial Habitats Act (all provisions). Discussed H.R. 8161, the Electric Ratepayer Funding Alternative Act (all provisions). Discussed H.R. 8159, the Abandoning Inconsistent and Rash Environmental Solutions Act (all provisions). Discussed H.R. 8156, the Queries Act (all provisions).
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of