Reported covered position: N/A
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 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.
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 · third_quarter · Q3
Discussed support for H.R. 7266/S. 5360, 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 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/H.R. 9806, 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/S. 5048, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed general support for legislative efforts to improve the permitting process, including the importance of the Federal Energy Regulatory Commission completing its portion of permitting reviews in a timely manner (no legislation). 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 the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities (no legislation). Discussed the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities in draft permitting reform legislation, the Bipartisan American Affordability and Jobs Act of 2026. 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 the cost drivers for transmission (no legislation). Discussed efforts by the Bonneville Power Administration to improve transmission and markets (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 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. 9340/S. 5028, 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 concerns with the expansion of must considers under section 111(d) of the Public Utility Regulatory Policies Act (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 5008, the Grid Connection and Congestion Management Act, to require regional transmission organizations and independent system operators administering an open access transmission tariff to offer basic access service for energy-only deliver (all provisions). Discussed S. 5199, the GRID Savings Act of 2026, to clarify the jurisdiction of the Federal Energy Regulatory Commission over the interconnection of large loads to the transmission system and provide for standards and procedures for the interconnection of large loads (all provisions). Discussed the tax implications of provisions in the bill that would impact public power. Discussed draft legislation that would establish a grant program at the Department of Energy and incentives at the Federal Energy Regulatory Commission to support the use of AI tools for utility cybersecurity purposes. 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 Electricity Subsector Coordinating Council governance and the importance of information sharing between the federal government and critical infrastructure. 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 support for the Low Income Home Energy Assistance Program (no legislation). Discussed draft legislation to create a national program for relief of utility arrears and collect data about electricity affordability from utilities (all provision). Discussed draft legislation to direct the Department of Energy and Environmental Protection Agency to study the impacts that data centers are having on rural areas. 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 when interconnecting data centers. Discussed the Presidents Ratepayer Protection Pledge. 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 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.
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 H.R. 1267, the PFAS Water Systems Liability Act, regarding how utilities are passive receivers of PFAS. Discussed the zero-liquid discharge requirements for certain waste streams under the Environmental Protection Agencys Steam Electric Effluent Limitation Guidelines (EPA-HQ-OW-2009-0819). Discussed Clean Water Act section 401 water quality certification rule and its importance to the power sector (EPA-HQ-OW-2025-2929). Discussed the importance of issuing a final rule defining Waters of the United States quickly (EPA-HQ-OW-2025-0322). Discussed EPAs proposed repeal of the Greenhouse Gas Standards for Fossil Fuel Fired Electric Generating Units (EPA-HQ-OAR-2025-0124; FRL-12674-01-OAR). Discussed support for the National Environmental Policy Act and Clean Water Act provisions in S. 4994, the American Energy and Mineral Infrastructure Act, to streamline permitting under the Natural Gas Act, the Federal Water Pollution Control Act, and the National Environmental Policy Act of 1969.
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 for H.R. 1897, the ESA Amendments Act of 2025, to amend the Endangered Species Act of 1973 to optimize conservation through resource prioritization, incentivize wildlife conservation on private lands, provide for greater incentives to recover listed species, create greater transparency and accountability in recovering listed species, streamline the permitting process, eliminate barriers to conservation, and restore congressional intent.
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 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.
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.
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 H.R. 1267, the PFAS Water Systems Liability Act, regarding how utilities are passive receivers of PFAS. Discussed the zero-liquid discharge requirements for certain waste streams under the Environmental Protection Agencys Steam Electric Effluent Limitation Guidelines (EPA-HQ-OW-2009-0819). Discussed Clean Water Act section 401 water quality certification rule and its importance to the power sector (EPA-HQ-OW-2025-2929). Discussed the importance of issuing a final rule defining Waters of the United States quickly (EPA-HQ-OW-2025-0322). Discussed EPAs proposed repeal of the Greenhouse Gas Standards for Fossil Fuel Fired Electric Generating Units (EPA-HQ-OAR-2025-0124; FRL-12674-01-OAR). Discussed support for the National Environmental Policy Act and Clean Water Act provisions in S. 4994, the American Energy and Mineral Infrastructure Act, to streamline permitting under the Natural Gas Act, the Federal Water Pollution Control Act, and the National Environmental Policy Act of 1969.
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 for H.R. 1897, the ESA Amendments Act of 2025, to amend the Endangered Species Act of 1973 to optimize conservation through resource prioritization, incentivize wildlife conservation on private lands, provide for greater incentives to recover listed species, create greater transparency and accountability in recovering listed species, streamline the permitting process, eliminate barriers to conservation, and restore congressional intent.
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.
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 for H.R. 1897, the ESA Amendments Act of 2025, to amend the Endangered Species Act of 1973 to optimize conservation through resource prioritization, incentivize wildlife conservation on private lands, provide for greater incentives to recover listed species, create greater transparency and accountability in recovering listed species, streamline the permitting process, eliminate barriers to conservation, and restore congressional intent.
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/S. 5360, 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 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/H.R. 9806, 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/S. 5048, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed general support for legislative efforts to improve the permitting process, including the importance of the Federal Energy Regulatory Commission completing its portion of permitting reviews in a timely manner (no legislation). 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 the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities (no legislation). Discussed the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities in draft permitting reform legislation, the Bipartisan American Affordability and Jobs Act of 2026. 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 the cost drivers for transmission (no legislation). Discussed efforts by the Bonneville Power Administration to improve transmission and markets (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 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. 9340/S. 5028, 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 concerns with the expansion of must considers under section 111(d) of the Public Utility Regulatory Policies Act (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 5008, the Grid Connection and Congestion Management Act, to require regional transmission organizations and independent system operators administering an open access transmission tariff to offer basic access service for energy-only deliver (all provisions). Discussed S. 5199, the GRID Savings Act of 2026, to clarify the jurisdiction of the Federal Energy Regulatory Commission over the interconnection of large loads to the transmission system and provide for standards and procedures for the interconnection of large loads (all provisions). Discussed the tax implications of provisions in the bill that would impact public power. Discussed draft legislation that would establish a grant program at the Department of Energy and incentives at the Federal Energy Regulatory Commission to support the use of AI tools for utility cybersecurity purposes. 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 Electricity Subsector Coordinating Council governance and the importance of information sharing between the federal government and critical infrastructure. 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 support for the Low Income Home Energy Assistance Program (no legislation). Discussed draft legislation to create a national program for relief of utility arrears and collect data about electricity affordability from utilities (all provision). Discussed draft legislation to direct the Department of Energy and Environmental Protection Agency to study the impacts that data centers are having on rural areas. 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 when interconnecting data centers. Discussed the Presidents Ratepayer Protection Pledge. Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives.
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/S. 5360, 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 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/H.R. 9806, 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/S. 5048, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed general support for legislative efforts to improve the permitting process, including the importance of the Federal Energy Regulatory Commission completing its portion of permitting reviews in a timely manner (no legislation). 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 the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities (no legislation). Discussed the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities in draft permitting reform legislation, the Bipartisan American Affordability and Jobs Act of 2026. 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 the cost drivers for transmission (no legislation). Discussed efforts by the Bonneville Power Administration to improve transmission and markets (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 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. 9340/S. 5028, 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 concerns with the expansion of must considers under section 111(d) of the Public Utility Regulatory Policies Act (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 5008, the Grid Connection and Congestion Management Act, to require regional transmission organizations and independent system operators administering an open access transmission tariff to offer basic access service for energy-only deliver (all provisions). Discussed S. 5199, the GRID Savings Act of 2026, to clarify the jurisdiction of the Federal Energy Regulatory Commission over the interconnection of large loads to the transmission system and provide for standards and procedures for the interconnection of large loads (all provisions). Discussed the tax implications of provisions in the bill that would impact public power. Discussed draft legislation that would establish a grant program at the Department of Energy and incentives at the Federal Energy Regulatory Commission to support the use of AI tools for utility cybersecurity purposes. 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 Electricity Subsector Coordinating Council governance and the importance of information sharing between the federal government and critical infrastructure. 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 support for the Low Income Home Energy Assistance Program (no legislation). Discussed draft legislation to create a national program for relief of utility arrears and collect data about electricity affordability from utilities (all provision). Discussed draft legislation to direct the Department of Energy and Environmental Protection Agency to study the impacts that data centers are having on rural areas. 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 when interconnecting data centers. Discussed the Presidents Ratepayer Protection Pledge. Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives.
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.
Hydropower Licensing Affordability Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 7266/S. 5360, 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 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/H.R. 9806, 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/S. 5048, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed general support for legislative efforts to improve the permitting process, including the importance of the Federal Energy Regulatory Commission completing its portion of permitting reviews in a timely manner (no legislation). 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 the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities (no legislation). Discussed the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities in draft permitting reform legislation, the Bipartisan American Affordability and Jobs Act of 2026. 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 the cost drivers for transmission (no legislation). Discussed efforts by the Bonneville Power Administration to improve transmission and markets (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 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. 9340/S. 5028, 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 concerns with the expansion of must considers under section 111(d) of the Public Utility Regulatory Policies Act (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 5008, the Grid Connection and Congestion Management Act, to require regional transmission organizations and independent system operators administering an open access transmission tariff to offer basic access service for energy-only deliver (all provisions). Discussed S. 5199, the GRID Savings Act of 2026, to clarify the jurisdiction of the Federal Energy Regulatory Commission over the interconnection of large loads to the transmission system and provide for standards and procedures for the interconnection of large loads (all provisions). Discussed the tax implications of provisions in the bill that would impact public power. Discussed draft legislation that would establish a grant program at the Department of Energy and incentives at the Federal Energy Regulatory Commission to support the use of AI tools for utility cybersecurity purposes. 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 Electricity Subsector Coordinating Council governance and the importance of information sharing between the federal government and critical infrastructure. 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 support for the Low Income Home Energy Assistance Program (no legislation). Discussed draft legislation to create a national program for relief of utility arrears and collect data about electricity affordability from utilities (all provision). Discussed draft legislation to direct the Department of Energy and Environmental Protection Agency to study the impacts that data centers are having on rural areas. 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 when interconnecting data centers. Discussed the Presidents Ratepayer Protection Pledge. Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives.
FLOWS Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 7266/S. 5360, 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 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/H.R. 9806, 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/S. 5048, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed general support for legislative efforts to improve the permitting process, including the importance of the Federal Energy Regulatory Commission completing its portion of permitting reviews in a timely manner (no legislation). 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 the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities (no legislation). Discussed the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities in draft permitting reform legislation, the Bipartisan American Affordability and Jobs Act of 2026. 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 the cost drivers for transmission (no legislation). Discussed efforts by the Bonneville Power Administration to improve transmission and markets (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 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. 9340/S. 5028, 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 concerns with the expansion of must considers under section 111(d) of the Public Utility Regulatory Policies Act (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 5008, the Grid Connection and Congestion Management Act, to require regional transmission organizations and independent system operators administering an open access transmission tariff to offer basic access service for energy-only deliver (all provisions). Discussed S. 5199, the GRID Savings Act of 2026, to clarify the jurisdiction of the Federal Energy Regulatory Commission over the interconnection of large loads to the transmission system and provide for standards and procedures for the interconnection of large loads (all provisions). Discussed the tax implications of provisions in the bill that would impact public power. Discussed draft legislation that would establish a grant program at the Department of Energy and incentives at the Federal Energy Regulatory Commission to support the use of AI tools for utility cybersecurity purposes. 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 Electricity Subsector Coordinating Council governance and the importance of information sharing between the federal government and critical infrastructure. 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 support for the Low Income Home Energy Assistance Program (no legislation). Discussed draft legislation to create a national program for relief of utility arrears and collect data about electricity affordability from utilities (all provision). Discussed draft legislation to direct the Department of Energy and Environmental Protection Agency to study the impacts that data centers are having on rural areas. 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 when interconnecting data centers. Discussed the Presidents Ratepayer Protection Pledge. Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives.
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.
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.
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 support for H.R. 7266/S. 5360, 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 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/H.R. 9806, 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/S. 5048, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed general support for legislative efforts to improve the permitting process, including the importance of the Federal Energy Regulatory Commission completing its portion of permitting reviews in a timely manner (no legislation). 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 the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities (no legislation). Discussed the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities in draft permitting reform legislation, the Bipartisan American Affordability and Jobs Act of 2026. 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 the cost drivers for transmission (no legislation). Discussed efforts by the Bonneville Power Administration to improve transmission and markets (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 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. 9340/S. 5028, 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 concerns with the expansion of must considers under section 111(d) of the Public Utility Regulatory Policies Act (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 5008, the Grid Connection and Congestion Management Act, to require regional transmission organizations and independent system operators administering an open access transmission tariff to offer basic access service for energy-only deliver (all provisions). Discussed S. 5199, the GRID Savings Act of 2026, to clarify the jurisdiction of the Federal Energy Regulatory Commission over the interconnection of large loads to the transmission system and provide for standards and procedures for the interconnection of large loads (all provisions). Discussed the tax implications of provisions in the bill that would impact public power. Discussed draft legislation that would establish a grant program at the Department of Energy and incentives at the Federal Energy Regulatory Commission to support the use of AI tools for utility cybersecurity purposes. 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 Electricity Subsector Coordinating Council governance and the importance of information sharing between the federal government and critical infrastructure. 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 support for the Low Income Home Energy Assistance Program (no legislation). Discussed draft legislation to create a national program for relief of utility arrears and collect data about electricity affordability from utilities (all provision). Discussed draft legislation to direct the Department of Energy and Environmental Protection Agency to study the impacts that data centers are having on rural areas. 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 when interconnecting data centers. Discussed the Presidents Ratepayer Protection Pledge. 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.
Hydropower Licensing Affordability Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 7266/S. 5360, 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 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/H.R. 9806, 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/S. 5048, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed general support for legislative efforts to improve the permitting process, including the importance of the Federal Energy Regulatory Commission completing its portion of permitting reviews in a timely manner (no legislation). 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 the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities (no legislation). Discussed the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities in draft permitting reform legislation, the Bipartisan American Affordability and Jobs Act of 2026. 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 the cost drivers for transmission (no legislation). Discussed efforts by the Bonneville Power Administration to improve transmission and markets (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 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. 9340/S. 5028, 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 concerns with the expansion of must considers under section 111(d) of the Public Utility Regulatory Policies Act (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 5008, the Grid Connection and Congestion Management Act, to require regional transmission organizations and independent system operators administering an open access transmission tariff to offer basic access service for energy-only deliver (all provisions). Discussed S. 5199, the GRID Savings Act of 2026, to clarify the jurisdiction of the Federal Energy Regulatory Commission over the interconnection of large loads to the transmission system and provide for standards and procedures for the interconnection of large loads (all provisions). Discussed the tax implications of provisions in the bill that would impact public power. Discussed draft legislation that would establish a grant program at the Department of Energy and incentives at the Federal Energy Regulatory Commission to support the use of AI tools for utility cybersecurity purposes. 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 Electricity Subsector Coordinating Council governance and the importance of information sharing between the federal government and critical infrastructure. 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 support for the Low Income Home Energy Assistance Program (no legislation). Discussed draft legislation to create a national program for relief of utility arrears and collect data about electricity affordability from utilities (all provision). Discussed draft legislation to direct the Department of Energy and Environmental Protection Agency to study the impacts that data centers are having on rural areas. 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 when interconnecting data centers. Discussed the Presidents Ratepayer Protection Pledge. Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives.
Rural and Municipal Utility Cybersecurity Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 7266/S. 5360, 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 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/H.R. 9806, 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/S. 5048, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed general support for legislative efforts to improve the permitting process, including the importance of the Federal Energy Regulatory Commission completing its portion of permitting reviews in a timely manner (no legislation). 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 the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities (no legislation). Discussed the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities in draft permitting reform legislation, the Bipartisan American Affordability and Jobs Act of 2026. 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 the cost drivers for transmission (no legislation). Discussed efforts by the Bonneville Power Administration to improve transmission and markets (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 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. 9340/S. 5028, 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 concerns with the expansion of must considers under section 111(d) of the Public Utility Regulatory Policies Act (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 5008, the Grid Connection and Congestion Management Act, to require regional transmission organizations and independent system operators administering an open access transmission tariff to offer basic access service for energy-only deliver (all provisions). Discussed S. 5199, the GRID Savings Act of 2026, to clarify the jurisdiction of the Federal Energy Regulatory Commission over the interconnection of large loads to the transmission system and provide for standards and procedures for the interconnection of large loads (all provisions). Discussed the tax implications of provisions in the bill that would impact public power. Discussed draft legislation that would establish a grant program at the Department of Energy and incentives at the Federal Energy Regulatory Commission to support the use of AI tools for utility cybersecurity purposes. 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 Electricity Subsector Coordinating Council governance and the importance of information sharing between the federal government and critical infrastructure. 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 support for the Low Income Home Energy Assistance Program (no legislation). Discussed draft legislation to create a national program for relief of utility arrears and collect data about electricity affordability from utilities (all provision). Discussed draft legislation to direct the Department of Energy and Environmental Protection Agency to study the impacts that data centers are having on rural areas. 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 when interconnecting data centers. Discussed the Presidents Ratepayer Protection Pledge. Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives.
To direct the Administrator of the Federal Aviation Administration to include medications and medical equipment for the emergency treatment of known or suspected opioid overdose in aircraft emergency medical kits, and for other purposes.
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 7266/S. 5360, 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 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/H.R. 9806, 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/S. 5048, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed general support for legislative efforts to improve the permitting process, including the importance of the Federal Energy Regulatory Commission completing its portion of permitting reviews in a timely manner (no legislation). 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 the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities (no legislation). Discussed the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities in draft permitting reform legislation, the Bipartisan American Affordability and Jobs Act of 2026. 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 the cost drivers for transmission (no legislation). Discussed efforts by the Bonneville Power Administration to improve transmission and markets (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 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. 9340/S. 5028, 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 concerns with the expansion of must considers under section 111(d) of the Public Utility Regulatory Policies Act (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 5008, the Grid Connection and Congestion Management Act, to require regional transmission organizations and independent system operators administering an open access transmission tariff to offer basic access service for energy-only deliver (all provisions). Discussed S. 5199, the GRID Savings Act of 2026, to clarify the jurisdiction of the Federal Energy Regulatory Commission over the interconnection of large loads to the transmission system and provide for standards and procedures for the interconnection of large loads (all provisions). Discussed the tax implications of provisions in the bill that would impact public power. Discussed draft legislation that would establish a grant program at the Department of Energy and incentives at the Federal Energy Regulatory Commission to support the use of AI tools for utility cybersecurity purposes. 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 Electricity Subsector Coordinating Council governance and the importance of information sharing between the federal government and critical infrastructure. 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 support for the Low Income Home Energy Assistance Program (no legislation). Discussed draft legislation to create a national program for relief of utility arrears and collect data about electricity affordability from utilities (all provision). Discussed draft legislation to direct the Department of Energy and Environmental Protection Agency to study the impacts that data centers are having on rural areas. 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 when interconnecting data centers. Discussed the Presidents Ratepayer Protection Pledge. Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives.
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.
Nutria Eradication and Control Reauthorization Act of 2024
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 7266/S. 5360, 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 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/H.R. 9806, 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/S. 5048, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed general support for legislative efforts to improve the permitting process, including the importance of the Federal Energy Regulatory Commission completing its portion of permitting reviews in a timely manner (no legislation). 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 the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities (no legislation). Discussed the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities in draft permitting reform legislation, the Bipartisan American Affordability and Jobs Act of 2026. 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 the cost drivers for transmission (no legislation). Discussed efforts by the Bonneville Power Administration to improve transmission and markets (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 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. 9340/S. 5028, 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 concerns with the expansion of must considers under section 111(d) of the Public Utility Regulatory Policies Act (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 5008, the Grid Connection and Congestion Management Act, to require regional transmission organizations and independent system operators administering an open access transmission tariff to offer basic access service for energy-only deliver (all provisions). Discussed S. 5199, the GRID Savings Act of 2026, to clarify the jurisdiction of the Federal Energy Regulatory Commission over the interconnection of large loads to the transmission system and provide for standards and procedures for the interconnection of large loads (all provisions). Discussed the tax implications of provisions in the bill that would impact public power. Discussed draft legislation that would establish a grant program at the Department of Energy and incentives at the Federal Energy Regulatory Commission to support the use of AI tools for utility cybersecurity purposes. 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 Electricity Subsector Coordinating Council governance and the importance of information sharing between the federal government and critical infrastructure. 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 support for the Low Income Home Energy Assistance Program (no legislation). Discussed draft legislation to create a national program for relief of utility arrears and collect data about electricity affordability from utilities (all provision). Discussed draft legislation to direct the Department of Energy and Environmental Protection Agency to study the impacts that data centers are having on rural areas. 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 when interconnecting data centers. Discussed the Presidents Ratepayer Protection Pledge. Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives.
Supporting National Security with Spectrum Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 7266/S. 5360, 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 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/H.R. 9806, 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/S. 5048, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed general support for legislative efforts to improve the permitting process, including the importance of the Federal Energy Regulatory Commission completing its portion of permitting reviews in a timely manner (no legislation). 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 the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities (no legislation). Discussed the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities in draft permitting reform legislation, the Bipartisan American Affordability and Jobs Act of 2026. 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 the cost drivers for transmission (no legislation). Discussed efforts by the Bonneville Power Administration to improve transmission and markets (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 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. 9340/S. 5028, 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 concerns with the expansion of must considers under section 111(d) of the Public Utility Regulatory Policies Act (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 5008, the Grid Connection and Congestion Management Act, to require regional transmission organizations and independent system operators administering an open access transmission tariff to offer basic access service for energy-only deliver (all provisions). Discussed S. 5199, the GRID Savings Act of 2026, to clarify the jurisdiction of the Federal Energy Regulatory Commission over the interconnection of large loads to the transmission system and provide for standards and procedures for the interconnection of large loads (all provisions). Discussed the tax implications of provisions in the bill that would impact public power. Discussed draft legislation that would establish a grant program at the Department of Energy and incentives at the Federal Energy Regulatory Commission to support the use of AI tools for utility cybersecurity purposes. 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 Electricity Subsector Coordinating Council governance and the importance of information sharing between the federal government and critical infrastructure. 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 support for the Low Income Home Energy Assistance Program (no legislation). Discussed draft legislation to create a national program for relief of utility arrears and collect data about electricity affordability from utilities (all provision). Discussed draft legislation to direct the Department of Energy and Environmental Protection Agency to study the impacts that data centers are having on rural areas. 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 when interconnecting data centers. Discussed the Presidents Ratepayer Protection Pledge. Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives.
Meals for At-Risk Americans Act of 2023
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 7266/S. 5360, 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 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/H.R. 9806, 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/S. 5048, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed general support for legislative efforts to improve the permitting process, including the importance of the Federal Energy Regulatory Commission completing its portion of permitting reviews in a timely manner (no legislation). 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 the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities (no legislation). Discussed the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities in draft permitting reform legislation, the Bipartisan American Affordability and Jobs Act of 2026. 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 the cost drivers for transmission (no legislation). Discussed efforts by the Bonneville Power Administration to improve transmission and markets (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 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. 9340/S. 5028, 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 concerns with the expansion of must considers under section 111(d) of the Public Utility Regulatory Policies Act (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 5008, the Grid Connection and Congestion Management Act, to require regional transmission organizations and independent system operators administering an open access transmission tariff to offer basic access service for energy-only deliver (all provisions). Discussed S. 5199, the GRID Savings Act of 2026, to clarify the jurisdiction of the Federal Energy Regulatory Commission over the interconnection of large loads to the transmission system and provide for standards and procedures for the interconnection of large loads (all provisions). Discussed the tax implications of provisions in the bill that would impact public power. Discussed draft legislation that would establish a grant program at the Department of Energy and incentives at the Federal Energy Regulatory Commission to support the use of AI tools for utility cybersecurity purposes. 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 Electricity Subsector Coordinating Council governance and the importance of information sharing between the federal government and critical infrastructure. 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 support for the Low Income Home Energy Assistance Program (no legislation). Discussed draft legislation to create a national program for relief of utility arrears and collect data about electricity affordability from utilities (all provision). Discussed draft legislation to direct the Department of Energy and Environmental Protection Agency to study the impacts that data centers are having on rural areas. 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 when interconnecting data centers. Discussed the Presidents Ratepayer Protection Pledge. 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.
Energy Permitting Reform Act of 2024
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 7266/S. 5360, 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 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/H.R. 9806, 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/S. 5048, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed general support for legislative efforts to improve the permitting process, including the importance of the Federal Energy Regulatory Commission completing its portion of permitting reviews in a timely manner (no legislation). 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 the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities (no legislation). Discussed the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities in draft permitting reform legislation, the Bipartisan American Affordability and Jobs Act of 2026. 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 the cost drivers for transmission (no legislation). Discussed efforts by the Bonneville Power Administration to improve transmission and markets (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 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. 9340/S. 5028, 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 concerns with the expansion of must considers under section 111(d) of the Public Utility Regulatory Policies Act (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 5008, the Grid Connection and Congestion Management Act, to require regional transmission organizations and independent system operators administering an open access transmission tariff to offer basic access service for energy-only deliver (all provisions). Discussed S. 5199, the GRID Savings Act of 2026, to clarify the jurisdiction of the Federal Energy Regulatory Commission over the interconnection of large loads to the transmission system and provide for standards and procedures for the interconnection of large loads (all provisions). Discussed the tax implications of provisions in the bill that would impact public power. Discussed draft legislation that would establish a grant program at the Department of Energy and incentives at the Federal Energy Regulatory Commission to support the use of AI tools for utility cybersecurity purposes. 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 Electricity Subsector Coordinating Council governance and the importance of information sharing between the federal government and critical infrastructure. 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 support for the Low Income Home Energy Assistance Program (no legislation). Discussed draft legislation to create a national program for relief of utility arrears and collect data about electricity affordability from utilities (all provision). Discussed draft legislation to direct the Department of Energy and Environmental Protection Agency to study the impacts that data centers are having on rural areas. 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 when interconnecting data centers. Discussed the Presidents Ratepayer Protection Pledge. Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives.
A bill to amend the Internal Revenue Code of 1986 to modify the railroad track maintenance credit.
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 7266/S. 5360, 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 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/H.R. 9806, 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/S. 5048, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed general support for legislative efforts to improve the permitting process, including the importance of the Federal Energy Regulatory Commission completing its portion of permitting reviews in a timely manner (no legislation). 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 the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities (no legislation). Discussed the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities in draft permitting reform legislation, the Bipartisan American Affordability and Jobs Act of 2026. 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 the cost drivers for transmission (no legislation). Discussed efforts by the Bonneville Power Administration to improve transmission and markets (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 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. 9340/S. 5028, 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 concerns with the expansion of must considers under section 111(d) of the Public Utility Regulatory Policies Act (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 5008, the Grid Connection and Congestion Management Act, to require regional transmission organizations and independent system operators administering an open access transmission tariff to offer basic access service for energy-only deliver (all provisions). Discussed S. 5199, the GRID Savings Act of 2026, to clarify the jurisdiction of the Federal Energy Regulatory Commission over the interconnection of large loads to the transmission system and provide for standards and procedures for the interconnection of large loads (all provisions). Discussed the tax implications of provisions in the bill that would impact public power. Discussed draft legislation that would establish a grant program at the Department of Energy and incentives at the Federal Energy Regulatory Commission to support the use of AI tools for utility cybersecurity purposes. 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 Electricity Subsector Coordinating Council governance and the importance of information sharing between the federal government and critical infrastructure. 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 support for the Low Income Home Energy Assistance Program (no legislation). Discussed draft legislation to create a national program for relief of utility arrears and collect data about electricity affordability from utilities (all provision). Discussed draft legislation to direct the Department of Energy and Environmental Protection Agency to study the impacts that data centers are having on rural areas. 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 when interconnecting data centers. Discussed the Presidents Ratepayer Protection Pledge. Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives.
Federal Contractor Cybersecurity Vulnerability Reduction Act of 2024
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 7266/S. 5360, 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 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/H.R. 9806, 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/S. 5048, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed general support for legislative efforts to improve the permitting process, including the importance of the Federal Energy Regulatory Commission completing its portion of permitting reviews in a timely manner (no legislation). 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 the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities (no legislation). Discussed the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities in draft permitting reform legislation, the Bipartisan American Affordability and Jobs Act of 2026. 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 the cost drivers for transmission (no legislation). Discussed efforts by the Bonneville Power Administration to improve transmission and markets (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 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. 9340/S. 5028, 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 concerns with the expansion of must considers under section 111(d) of the Public Utility Regulatory Policies Act (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 5008, the Grid Connection and Congestion Management Act, to require regional transmission organizations and independent system operators administering an open access transmission tariff to offer basic access service for energy-only deliver (all provisions). Discussed S. 5199, the GRID Savings Act of 2026, to clarify the jurisdiction of the Federal Energy Regulatory Commission over the interconnection of large loads to the transmission system and provide for standards and procedures for the interconnection of large loads (all provisions). Discussed the tax implications of provisions in the bill that would impact public power. Discussed draft legislation that would establish a grant program at the Department of Energy and incentives at the Federal Energy Regulatory Commission to support the use of AI tools for utility cybersecurity purposes. 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 Electricity Subsector Coordinating Council governance and the importance of information sharing between the federal government and critical infrastructure. 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 support for the Low Income Home Energy Assistance Program (no legislation). Discussed draft legislation to create a national program for relief of utility arrears and collect data about electricity affordability from utilities (all provision). Discussed draft legislation to direct the Department of Energy and Environmental Protection Agency to study the impacts that data centers are having on rural areas. 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 when interconnecting data centers. Discussed the Presidents Ratepayer Protection Pledge. Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives.
Fair Flood Protection Act of 2024
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 7266/S. 5360, 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 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/H.R. 9806, 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/S. 5048, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed general support for legislative efforts to improve the permitting process, including the importance of the Federal Energy Regulatory Commission completing its portion of permitting reviews in a timely manner (no legislation). 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 the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities (no legislation). Discussed the importance of maintaining the current treatment of Federal Power Act section 201(f) non-jurisdictional entities in draft permitting reform legislation, the Bipartisan American Affordability and Jobs Act of 2026. 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 the cost drivers for transmission (no legislation). Discussed efforts by the Bonneville Power Administration to improve transmission and markets (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 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. 9340/S. 5028, 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 concerns with the expansion of must considers under section 111(d) of the Public Utility Regulatory Policies Act (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 5008, the Grid Connection and Congestion Management Act, to require regional transmission organizations and independent system operators administering an open access transmission tariff to offer basic access service for energy-only deliver (all provisions). Discussed S. 5199, the GRID Savings Act of 2026, to clarify the jurisdiction of the Federal Energy Regulatory Commission over the interconnection of large loads to the transmission system and provide for standards and procedures for the interconnection of large loads (all provisions). Discussed the tax implications of provisions in the bill that would impact public power. Discussed draft legislation that would establish a grant program at the Department of Energy and incentives at the Federal Energy Regulatory Commission to support the use of AI tools for utility cybersecurity purposes. 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 Electricity Subsector Coordinating Council governance and the importance of information sharing between the federal government and critical infrastructure. 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 support for the Low Income Home Energy Assistance Program (no legislation). Discussed draft legislation to create a national program for relief of utility arrears and collect data about electricity affordability from utilities (all provision). Discussed draft legislation to direct the Department of Energy and Environmental Protection Agency to study the impacts that data centers are having on rural areas. 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 when interconnecting data centers. Discussed the Presidents Ratepayer Protection Pledge. 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.
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 the provisions the Senate version of H.R. 1, the One Big Beautiful Bill Act, to auction licenses in the 6 gigahertz (GHz) band and the potential impact it could have on public power utilities that rely on the 6 GHz band for critical utility communications. Discussed how House version of H.R. 1 did not include similar language.
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 concerns with third-party efforts to remove the Lower Snake River Dams and the importance of hydropower (no bill). Discussed President Trumps Executive Order, Empowering Commonsense Wildfire Prevention and Response, and APPAs support for efforts to improve interagency coordination on wildfires. Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusions for vegetation management along power line rights-of-way on federal lands. Discussed support for H.R. 2492, the Fire Safe Electrical Corridors Act of 2025 (all provisions). Discussed concerns with section 60062 in H.R. 1, the One Big Beautiful Bill Act, provision to allow for faster review of environmental assessments and environmental impact statements under the National Environmental Policy Act. Discussed H.R. 3637, the Locally Led Restoration Act of 2025, to allow public and private entities to enter into stewardship contracts with the Forest Service and the Bureau of Land Management if the goals of a project include the removal of vegetation and at least 10 percent of the vegetation proposed to be removed is salvage, meaning wildfire kill, beetle kill, and dead or dying organic material.
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.
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 the proposed rulemaking to revise the definition of Waters of the United States and implementation changes. Also discussed ways to strengthen the proposal (Docket ID No.: EPA-OW-2025-0322; FRL 11132.1-01-OW).
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 NEPA (all provisions). 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 importance of the Endangered Species Act for public power utilities and some of the challenges the statute creates (Docket No. FWS-HQ-ES-2025-0039, FWS-HQ-ES-2025-0048, FWS-HQ-ES-2025-0029, and FWS-HQ-ES-2025-0044).
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.
Fire Safe Electrical Corridors Act of 2025
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 President Trumps Executive Order, Empowering Commonsense Wildfire Prevention and Response, and APPAs support for efforts to improve interagency coordination on wildfires. Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusions for vegetation management along power line rights-of-way on federal lands. Discussed support for H.R. 2492, the Fire Safe Electrical Corridors Act of 2025 (all provisions). Discussed concerns with section 60062 in H.R. 1, the One Big Beautiful Bill Act, provision to allow for faster review of environmental assessments and environmental impact statements under the National Environmental Policy Act. Discussed H.R. 3637, the Locally Led Restoration Act of 2025, to allow public and private entities to enter into stewardship contracts with the Forest Service and the Bureau of Land Management if the goals of a project include the removal of vegetation and at least 10 percent of the vegetation proposed to be removed is salvage, meaning wildfire kill, beetle kill, and dead or dying organic material.
Religious Workforce Protection Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
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. 2836, 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 the need for FEMA reform (no legislation). Provided feedback on draft legislation, the Fixing Emergency Management for Americans (FEMA) Act, including section 101, to replace existing section 406 cost-based grants with new Stafford Act section 409 estimate-based grants and section 301, expanding preapproved hazard mitigation lists to include public power. Also discussed section 117 on expedited funding for emergency work, section 118 to clarify the definition of local in constancy in procurement practices, and section 122 on loan interest payment relief. Discussed support for H.R. 4669, the FEMA Act (all provisions), including section 101 on rebuilding public infrastructure. Provided feedback on draft legislation to reform the Stafford Act to allow for better grid technology when rebuilding downed power lines after a disaster. Discussed the termination of the Building Resilient Infrastructure and Communities program at FEMA, which provides funding to support eligible entities undertaking pre-disaster and hazard mitigation projects or capability and capacity building activities to reduce their risks from disasters and natural hazards.
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 (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. 2836, 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 the need for FEMA reform (no legislation). Provided feedback on draft legislation, the Fixing Emergency Management for Americans (FEMA) Act, including section 101, to replace existing section 406 cost-based grants with new Stafford Act section 409 estimate-based grants and section 301, expanding preapproved hazard mitigation lists to include public power. Also discussed section 117 on expedited funding for emergency work, section 118 to clarify the definition of local in constancy in procurement practices, and section 122 on loan interest payment relief. Discussed support for H.R. 4669, the FEMA Act (all provisions), including section 101 on rebuilding public infrastructure. Provided feedback on draft legislation to reform the Stafford Act to allow for better grid technology when rebuilding downed power lines after a disaster. Discussed the termination of the Building Resilient Infrastructure and Communities program at FEMA, which provides funding to support eligible entities undertaking pre-disaster and hazard mitigation projects or capability and capacity building activities to reduce their risks from disasters and natural hazards.
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.
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).
Locally Led Restoration Act of 2025
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 President Trumps Executive Order, Empowering Commonsense Wildfire Prevention and Response, and APPAs support for efforts to improve interagency coordination on wildfires. Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusions for vegetation management along power line rights-of-way on federal lands. Discussed support for H.R. 2492, the Fire Safe Electrical Corridors Act of 2025 (all provisions). Discussed concerns with section 60062 in H.R. 1, the One Big Beautiful Bill Act, provision to allow for faster review of environmental assessments and environmental impact statements under the National Environmental Policy Act. Discussed H.R. 3637, the Locally Led Restoration Act of 2025, to allow public and private entities to enter into stewardship contracts with the Forest Service and the Bureau of Land Management if the goals of a project include the removal of vegetation and at least 10 percent of the vegetation proposed to be removed is salvage, meaning wildfire kill, beetle kill, and dead or dying organic material.
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).
PERMIT Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed general support for the repeal of the 2024 Carbon Pollution Standard (Docket No. EPA-HQ-OAR-2025-0124). Discussed the potential reliability impacts from the rule, as well impracticality of using carbon capture and storage technology to reduce emissions given the current state of the technology. Discussed concerns with the 2024 Effluent Limitation Guidelines Rule and the costs of various waterwater treatment technologies required to comply with the rule (Docket No. EPA-HQ-OW-2009-0819). Discussed the administrations plans to reconsider the rule and the challenges with meeting the compliance deadlines in the 2024 rule. Discussed and provided feedback on draft legislation to amend the Clean Water Act to improve the federal permitting process. Discussed support for H.R. 3898, the PERMIT Act, to improve the permitting process for infrastructure projects under the Clean Water Act, provision regarding nationwide permitting and the determination of the appropriate acreage threshold for discharges into WOTUS, and provision regarding section 18 statutory exclusion from the regulatory definition of WOTUS for waste treatment systems. Also discussed section 6, clarifying federal general permits, and section 15, judicial review timelines clarity. Discussed proposal by the Army Corps of Engineers to reissue or modify the 2021 Nationwide Permits (NWPs) under section 404 of the Clean Water Act and section 10 of the Rivers and Harbor Act of 1899. Discussed the need to quickly issue and finalize an NWP rulemaking to assist energy infrastructure projects (DOE/COE; RIN 0710-AB56).
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 the proposed rulemaking to revise the definition of Waters of the United States and implementation changes. Also discussed ways to strengthen the proposal (Docket ID No.: EPA-OW-2025-0322; FRL 11132.1-01-OW).
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 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.
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 amending the definition of building codes as used in determining eligible permanent work under proposed section 409 to include electric power utility standards in H.R. 4669, the FEMA Act. Discussed concerns with possible changes to the Stafford Act to allow the recoupment of recovery costs. Discussed the impact to public power utilities of Building Resilient Infrastructure and Communities grant cancellations.
FEMA Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
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. 2836, 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 the need for FEMA reform (no legislation). Provided feedback on draft legislation, the Fixing Emergency Management for Americans (FEMA) Act, including section 101, to replace existing section 406 cost-based grants with new Stafford Act section 409 estimate-based grants and section 301, expanding preapproved hazard mitigation lists to include public power. Also discussed section 117 on expedited funding for emergency work, section 118 to clarify the definition of local in constancy in procurement practices, and section 122 on loan interest payment relief. Discussed support for H.R. 4669, the FEMA Act (all provisions), including section 101 on rebuilding public infrastructure. Provided feedback on draft legislation to reform the Stafford Act to allow for better grid technology when rebuilding downed power lines after a disaster. Discussed the termination of the Building Resilient Infrastructure and Communities program at FEMA, which provides funding to support eligible entities undertaking pre-disaster and hazard mitigation projects or capability and capacity building activities to reduce their risks from disasters and natural hazards.
Fix Our Forests 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 President Trumps Executive Order, Empowering Commonsense Wildfire Prevention and Response, and APPAs support for efforts to improve interagency coordination on wildfires. Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusions for vegetation management along power line rights-of-way on federal lands. Discussed support for H.R. 2492, the Fire Safe Electrical Corridors Act of 2025 (all provisions). Discussed concerns with section 60062 in H.R. 1, the One Big Beautiful Bill Act, provision to allow for faster review of environmental assessments and environmental impact statements under the National Environmental Policy Act. Discussed H.R. 3637, the Locally Led Restoration Act of 2025, to allow public and private entities to enter into stewardship contracts with the Forest Service and the Bureau of Land Management if the goals of a project include the removal of vegetation and at least 10 percent of the vegetation proposed to be removed is salvage, meaning wildfire kill, beetle kill, and dead or dying organic material.
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 NEPA (all provisions). 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 importance of the Endangered Species Act for public power utilities and some of the challenges the statute creates (Docket No. FWS-HQ-ES-2025-0039, FWS-HQ-ES-2025-0048, FWS-HQ-ES-2025-0029, and FWS-HQ-ES-2025-0044).
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).
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.
Fix Our Forests 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 President Trumps Executive Order, Empowering Commonsense Wildfire Prevention and Response, and APPAs support for efforts to improve interagency coordination on wildfires. Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusions for vegetation management along power line rights-of-way on federal lands. Discussed support for H.R. 2492, the Fire Safe Electrical Corridors Act of 2025 (all provisions). Discussed concerns with section 60062 in H.R. 1, the One Big Beautiful Bill Act, provision to allow for faster review of environmental assessments and environmental impact statements under the National Environmental Policy Act. Discussed H.R. 3637, the Locally Led Restoration Act of 2025, to allow public and private entities to enter into stewardship contracts with the Forest Service and the Bureau of Land Management if the goals of a project include the removal of vegetation and at least 10 percent of the vegetation proposed to be removed is salvage, meaning wildfire kill, beetle kill, and dead or dying organic material.
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.
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 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.
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).
Limit, Save, Grow Act of 2023
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 section 242 of H.R. 2811, the Limit, Save, Grow Act of 2023, that would repeal the taxpayer election of payments, in lieu of credits, for specified energy property and production of electricity from certain renewable resources. Discussion of 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 Treasury guidance relating to utility assistance use of funding under section 5001 of the CARES Act (Coronavirus State and Local Fiscal Relief Funds) as amended by the Consolidated Appropriations Act of 2020. Discussed support for H.R. 1837, the Investing in Our Communities Act to reinstate the ability to issue tax-exempt advance refunding bonds (all provisions). Discussed support for S. 1453, the Lifting Our Communities through Advance Liquidity for Infrastructure Act (LOCAL Infrastructure Act), to reinstate the ability to issue tax-exempt advance refunding bonds (all provisions). Discussed support for potential legislation to increase the small-issuer exception from $10 million to $30 million. Discussed concerns with Proposed Rule: Section 45V Credit for Production of Clean Hydrogen; Section 48(a)(15) Election to Treat Clean Hydrogen Production Facilities as Energy Property (88 FR 8920, REG-117631-23 (additionality requirements for clean power used to generate hydrogen).
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 concerns with the DOEs proposed energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they would worsen the distribution transformer supply chain crisis. 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 support for S. 3627, the Distribution Transformer Efficiency and Supply Chain Reliability Act of 2024 (all provisions). Discussed the need for the FAQS for the Fiscal Years 2022-2023 Funding Cycle for the Department of Energy's Grid Resilience and Innovation Partnerships (GRIP) Program (P.L. 117-58, sections 40101, 40103, and 40107) to be clarified regarding eligibility for joint action agencies. Discussed support for DOE's GRIP Program (P.L. 117-58, sections 40101, 40103, and 40107). Discussed ways to improve DOE outreach to smaller and rural utilities. Discussed the importance of improving the hydropower licensing and relicensing process (no bill). 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, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed H.R. 6185, the Guaranteeing Reliable Infrastructure Development (GRID) 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 making transmission investment tax credits refundable in CETA, direct pay tax credits. 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 concerns with 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 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 across the U.S. Discussed the development of Western markets. Discussed President Bidens Executive Order to promote the safe, secure, and trustworthy development and use of artificial intelligence (AI). Discussed the potential use of AI by electric utilities. Discussed the National Cyber Incident Response Plan. Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort. Also discussed concerns with how the federal permitting process is slowing the ability of NTUA and volunteers to connect additional Navajo Nation homes to the electric grid.
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.
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.
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 concerns with the DOEs proposed energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they would worsen the distribution transformer supply chain crisis. 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 support for S. 3627, the Distribution Transformer Efficiency and Supply Chain Reliability Act of 2024 (all provisions). Discussed the need for the FAQS for the Fiscal Years 2022-2023 Funding Cycle for the Department of Energy's Grid Resilience and Innovation Partnerships (GRIP) Program (P.L. 117-58, sections 40101, 40103, and 40107) to be clarified regarding eligibility for joint action agencies. Discussed support for DOE's GRIP Program (P.L. 117-58, sections 40101, 40103, and 40107). Discussed ways to improve DOE outreach to smaller and rural utilities. Discussed the importance of improving the hydropower licensing and relicensing process (no bill). 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, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed H.R. 6185, the Guaranteeing Reliable Infrastructure Development (GRID) 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 making transmission investment tax credits refundable in CETA, direct pay tax credits. 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 concerns with 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 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 across the U.S. Discussed the development of Western markets. Discussed President Bidens Executive Order to promote the safe, secure, and trustworthy development and use of artificial intelligence (AI). Discussed the potential use of AI by electric utilities. Discussed the National Cyber Incident Response Plan. Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort. Also discussed concerns with how the federal permitting process is slowing the ability of NTUA and volunteers to connect additional Navajo Nation homes to the electric grid.
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.
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 concerns with the DOEs proposed energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they would worsen the distribution transformer supply chain crisis. 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 support for S. 3627, the Distribution Transformer Efficiency and Supply Chain Reliability Act of 2024 (all provisions). Discussed the need for the FAQS for the Fiscal Years 2022-2023 Funding Cycle for the Department of Energy's Grid Resilience and Innovation Partnerships (GRIP) Program (P.L. 117-58, sections 40101, 40103, and 40107) to be clarified regarding eligibility for joint action agencies. Discussed support for DOE's GRIP Program (P.L. 117-58, sections 40101, 40103, and 40107). Discussed ways to improve DOE outreach to smaller and rural utilities. Discussed the importance of improving the hydropower licensing and relicensing process (no bill). 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, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed H.R. 6185, the Guaranteeing Reliable Infrastructure Development (GRID) 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 making transmission investment tax credits refundable in CETA, direct pay tax credits. 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 concerns with 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 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 across the U.S. Discussed the development of Western markets. Discussed President Bidens Executive Order to promote the safe, secure, and trustworthy development and use of artificial intelligence (AI). Discussed the potential use of AI by electric utilities. Discussed the National Cyber Incident Response Plan. Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort. Also discussed concerns with how the federal permitting process is slowing the ability of NTUA and volunteers to connect additional Navajo Nation homes to the electric grid.
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.
GRID 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 concerns with the DOEs proposed energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they would worsen the distribution transformer supply chain crisis. 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 support for S. 3627, the Distribution Transformer Efficiency and Supply Chain Reliability Act of 2024 (all provisions). Discussed the need for the FAQS for the Fiscal Years 2022-2023 Funding Cycle for the Department of Energy's Grid Resilience and Innovation Partnerships (GRIP) Program (P.L. 117-58, sections 40101, 40103, and 40107) to be clarified regarding eligibility for joint action agencies. Discussed support for DOE's GRIP Program (P.L. 117-58, sections 40101, 40103, and 40107). Discussed ways to improve DOE outreach to smaller and rural utilities. Discussed the importance of improving the hydropower licensing and relicensing process (no bill). 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, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed H.R. 6185, the Guaranteeing Reliable Infrastructure Development (GRID) 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 making transmission investment tax credits refundable in CETA, direct pay tax credits. 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 concerns with 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 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 across the U.S. Discussed the development of Western markets. Discussed President Bidens Executive Order to promote the safe, secure, and trustworthy development and use of artificial intelligence (AI). Discussed the potential use of AI by electric utilities. Discussed the National Cyber Incident Response Plan. Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort. Also discussed concerns with how the federal permitting process is slowing the ability of NTUA and volunteers to connect additional Navajo Nation homes to the electric grid.
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.
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.
Clean Electricity and Transmission Acceleration 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.
Clean Electricity and Transmission Acceleration 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 concerns with the DOEs proposed energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they would worsen the distribution transformer supply chain crisis. 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 support for S. 3627, the Distribution Transformer Efficiency and Supply Chain Reliability Act of 2024 (all provisions). Discussed the need for the FAQS for the Fiscal Years 2022-2023 Funding Cycle for the Department of Energy's Grid Resilience and Innovation Partnerships (GRIP) Program (P.L. 117-58, sections 40101, 40103, and 40107) to be clarified regarding eligibility for joint action agencies. Discussed support for DOE's GRIP Program (P.L. 117-58, sections 40101, 40103, and 40107). Discussed ways to improve DOE outreach to smaller and rural utilities. Discussed the importance of improving the hydropower licensing and relicensing process (no bill). 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, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed H.R. 6185, the Guaranteeing Reliable Infrastructure Development (GRID) 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 making transmission investment tax credits refundable in CETA, direct pay tax credits. 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 concerns with 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 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 across the U.S. Discussed the development of Western markets. Discussed President Bidens Executive Order to promote the safe, secure, and trustworthy development and use of artificial intelligence (AI). Discussed the potential use of AI by electric utilities. Discussed the National Cyber Incident Response Plan. Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort. Also discussed concerns with how the federal permitting process is slowing the ability of NTUA and volunteers to connect additional Navajo Nation homes to the electric grid.
Federal Bureau of Prisons Voting Assistance 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 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 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 Power Marketing Administration and their customers. Discussed support for S. 4016/H.R. 7776, the Help Hoover Dam Act (all provisions).
Filing targets: Energy, Dept of, Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), SENATE, Securities & Exchange Commission (SEC)
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.
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 H.R. 1267, the PFAS Water Systems Liability Act, regarding how utilities are passive receivers of PFAS. Discussed the zero-liquid discharge requirements for certain waste streams under the Environmental Protection Agencys Steam Electric Effluent Limitation Guidelines (EPA-HQ-OW-2009-0819). Discussed Clean Water Act section 401 water quality certification rule and its importance to the power sector (EPA-HQ-OW-2025-2929). Discussed the importance of issuing a final rule defining Waters of the United States quickly (EPA-HQ-OW-2025-0322). Discussed EPAs proposed repeal of the Greenhouse Gas Standards for Fossil Fuel Fired Electric Generating Units (EPA-HQ-OAR-2025-0124; FRL-12674-01-OAR). Discussed support for the National Environmental Policy Act and Clean Water Act provisions in S. 4994, the American Energy and Mineral Infrastructure Act, to streamline permitting under the Natural Gas Act, the Federal Water Pollution Control Act, and the National Environmental Policy Act of 1969.
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. 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 for H.R. 1897, the ESA Amendments Act of 2025, to amend the Endangered Species Act of 1973 to optimize conservation through resource prioritization, incentivize wildlife conservation on private lands, provide for greater incentives to recover listed species, create greater transparency and accountability in recovering listed species, streamline the permitting process, eliminate barriers to conservation, and restore congressional intent.
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. 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 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 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 concerns with section 102 of the H.R. 2289, the Proportional Review for Broadband Deployment Act, to use section 253 of the Communications Act of 1934 to effectively expand federal control over public power pole attachments. Discussed how the pole attachment process works for public power utilities (no legislation). Discussed reinforcing the municipal exemption from federal regulation of public power utility pole attachments under section 224 of the Communications Act of 1934. Discussed the potential impact of spectrum auctions on the use of the six gigahertz band, which is used for communications for critical infrastructure (no bill).
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. 4669, the FEMA Act (all provisions), including section 101 on rebuilding public infrastructure. Discussed support for amending the definition of building codes as used in determining eligible permanent work under proposed section 409 to include electric power utility standards in H.R. 4669, the FEMA Act. Discussed concerns with possible changes to the Stafford Act to allow the recoupment of recovery costs. Discussed the impact to public power utilities of Building Resilient Infrastructure and Communities grant cancellations.
Discussed support for H.R. 4776, the SPEED Act, to reform permitting processes under NEPA (all provisions). 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 importance of the Endangered Species Act for public power utilities and some of the challenges the statute creates (Docket No. FWS-HQ-ES-2025-0039, FWS-HQ-ES-2025-0048, FWS-HQ-ES-2025-0029, and FWS-HQ-ES-2025-0044).
Discussed opposition to H.R. 278, BROADBAND Leadership Act, to use section 253 of the Communications Act of 1934 to effectively gut the exemption in section 224, which prevents the Federal Communications Commission from regulating public power pole attachments. Discussed concerns with section 102 of the H.R. 2289, the Proportional Review for Broadband Deployment Act, which includes the text of H.R. 278.
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 the proposed rulemaking to revise the definition of Waters of the United States and implementation changes. Also discussed ways to strengthen the proposal (Docket ID No.: EPA-OW-2025-0322; FRL 11132.1-01-OW).
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
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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 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. 2836, 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 the need for FEMA reform (no legislation). Provided feedback on draft legislation, the Fixing Emergency Management for Americans (FEMA) Act, including section 101, to replace existing section 406 cost-based grants with new Stafford Act section 409 estimate-based grants and section 301, expanding preapproved hazard mitigation lists to include public power. Also discussed section 117 on expedited funding for emergency work, section 118 to clarify the definition of local in constancy in procurement practices, and section 122 on loan interest payment relief. Discussed support for H.R. 4669, the FEMA Act (all provisions), including section 101 on rebuilding public infrastructure. Provided feedback on draft legislation to reform the Stafford Act to allow for better grid technology when rebuilding downed power lines after a disaster. Discussed the termination of the Building Resilient Infrastructure and Communities program at FEMA, which provides funding to support eligible entities undertaking pre-disaster and hazard mitigation projects or capability and capacity building activities to reduce their risks from disasters and natural hazards.
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
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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.
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2024 · fourth_quarter · Q4
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.
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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.
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2024 · second_quarter · Q2
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.
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2024 · first_quarter · Q1
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 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 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 Power Marketing Administration and their customers. Discussed support for S. 4016/H.R. 7776, the Help Hoover Dam Act (all provisions).
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2023 · second_quarter · Q2
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 (DOE) 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 how strong industry-government partnerships should be supported to prevent, prepare for, and respond to cybersecurity attacks. Discussed how the federal government should play a greater role in helping electric utilities in assessing vendor cybersecurity practices, such as establishing a federal vendor certification or accreditation program. Discussed how Congress should refrain from imposing additional cyber incident reporting mandates until the Cybersecurity Incident Reporting for Critical Infrastructure Act (CIRCIA) is fully implemented. Provided feedback on H.R. 1160, the Critical Electric Infrastructure Cybersecurity Incident Reporting Act (all provisions). Discussed draft legislation to direct state public utility commissions to establish cybersecurity baselines for distribution utilities (no bill number). Discussed efforts by DOE and other stakeholders on cybersecurity baselines for distribution utilities. Discussed funding opportunities under the Rural and Municipal Utility Advanced Cybersecurity Grant Program. Discussed potential problems with the implementation of the Rural and Municipal Utility Grant Program at DOE (Sec. 40124(d)(1)(A) of the Infrastructure Investment and Jobs Act) regarding the provision of technical assistance. 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 DOE to address the distribution transformer supply chain crisis, including President Bidens declaration to use the Defense Production Act. Discussed concerns with the DOEs proposed energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they would worsen the distribution transformer supply chain crisis. Discussed need for increased domestic manufacturing of equipment for electric utilities. Discussed H.R. 763, the Supply CHAINS Act, and if the legislation could help address the distribution transformer supply chain issue. Discussed draft legislation, 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 public power utility access to additional funding for loans for renewable energy created under the Inflation Reduction Act (Pub. Law 117-169), section 22001. Discussed concerns with the DOEs draft guidance to implement section 247 (Maintaining and Enhancing Hydroelectric Incentives) in the Infrastructure Investment and Jobs Act (IIJA)(P.L. 117-58). Discussed, S. 1521, the Community and Hydropower Improvement, and provisions giving tribes mandatory conditioning authority. Discussed the importance of hydropower to rural public power communities. Provided feedback on unintroduced, updated version of legislation from the 117th Congress, the BIG WIRES Act, to give the Federal Energy Regulatory Commission (FERC) the authority to require the expansion of transmission facilities for reliability, among other things (all provisions). Discussed support for permitting reform to help expedite the construction of energy infrastructure (no bill), including changes to the National Environmental Policy Act and changes to the Federal Power Act to expedite the construction of transmission while not saddling public power utilities with transmission costs for which they receive no benefit. Provided feedback on draft legislation, the Clean Electricity Transmission Acceleration Act (all provisions), 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. Provided feedback on draft permitting reform legislation, the Building American Energy Security Act of 2023 (provisions on transmission). Provided feedback on draft legislation, the CHARGE Act, to promote transmission (all provisions). Discussed concerns with overly broad definitions of the benefits of transmission that would result in utilities and their customers paying for transmission projects from which they derive no benefit. Also discussed the importance of keeping costs affordable for customers. Discussed the importance of keeping rates affordable as new transmission infrastructure is developed. Discussed the importance of joint ownership opportunities for public power utilities as new transmission projects are being built. Discussed the importance of containing costs for customers for building new transmission to accommodate a changing resource mix and to promote reliability and resilience. Discussed concerns with language to set minimum interregional transfer capability between regions being included transmission legislation (no specific bill). Discussed the importance of permitting reform to help build clean energy infrastructure, which will reduce greenhouse gas emissions. Discussed public power programs to promote demand response. Discussed the domestic content requirements in the Inflation Reduction Act (IRA) and Build America requirements in the IIJA, specifically the unique rules that apply to public power and the co-ops. Discussed ensuring the U.S. has adequate natural gas pipeline infrastructure needed for electric reliability. Discussed the public power business model. Discussed how public power utilities are deploying electric vehicle charging infrastructure in their communities.
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2023 · first_quarter · Q1
Provided feedback on the permitting reform provisions in the Transparency and Production of American Energy Act of 2023 (draft legislation), which was folded into H.R. 1, the Lower Energy Costs Act. Provided feedback on the permitting reform provisions in the Builder Act (draft legislation), which was folded into H.R. 1, the Lower Energy Costs Act. Discussed the provisions in H.R. 1, the Lower Energy Costs Act, to reform NEPA and to make it easier to deal with hazard trees near electric infrastructure on federal lands. Discussed opposition to breaching the Lower Snake River Dams. Discussed the need to modernize and renegotiate the Columbia River Treaty. Discussed Council on Environmental Quality mediation on Columbia River System operations (no legislation). Discussed the competitiveness of Bonneville Power Administration rates and how that is impacting new preference customer contracts. Discussed impacts of fish mitigation on Bonneville Power Administration rates. Discussed the importance of the federal Power Marketing Administrations that provide federal hydropower to public power utilities. Discussed the problem of rising joint costs assigned by the Army Corps of Engineers to the Power Marketing Administrations and their federal hydropower customers. Discussed declining hydropower production in the West and the potential impacts to grid reliability in the West and power prices for preference customers.
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2022 · fourth_quarter · Q4
Discussed the need for appropriations for the Defense Production Act to help address the distribution transformer supply chain crisis, Fiscal Year 2023 Energy and Water Appropriations Bill, possible disaster supplemental bill, and Consolidated Appropriations Act, 2023. Discussed potential legislation to wave PAYGO sequestration of direct payment bonds and refundable tax credits. Discussed provision to delay PAYGO sequestration in H.R. 2617, Consolidated Appropriations Act, 2023. Discussed support for including supplemental appropriations for Western Area Power Administration to help address drought in H.R. 2617, Consolidated Appropriations Act, 2023
Discussed grid security issues, including implementation of the mandatory cyber incident reporting legislation (included in the Consolidated Appropriations Act, 2022 (H.R. 2471)) by the Department of Homeland Securitys Cybersecurity and Infrastructure Security Agency (DHS CISA) and the need to avoid duplicative or conflicting reporting requirements. Discussed the need for DHS CISA to undertake a careful and deliberative implementation process that takes into account existing reporting mandates and to appropriately tailor reporting mandates commensurate with risk to national security. Discussed H.R. 9234, the Critical Electric Infrastructure Cybersecurity Incident Reporting Act (all provisions). Discussed draft legislation to establish cybersecurity baselines for distribution utilities (no bill number). Discussed concerns with section 5207 in the House-passed Fiscal Year 2023 National Defense Authorization Act (H.R. 7900) on the establishment of systemically importance critical entities. Discussed potential amendments to H.R. 7776, the Fiscal Year 2023 National Defense Authorization Act, on establishing a threat analysis center at the Department of Energy and on establishing a national risk management cycle. Discussed how public power utilities can work with the Department of Homeland Security on critical infrastructure issues and grid security. Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed support for the Department of Energy temporarily waiving distribution transformer energy efficiency standards to help spread raw steel materials and increase production volumes. Discussed efforts at the Department of Energy to address the distribution transformer supply chain crisis, including President Bidens declaration to use the Defense Production Act. Discussed the need for appropriations for the Defense Production Act to help address the distribution transformer supply chain crisis, Fiscal Year 2023 Energy and Water Appropriations Bill, possible disaster supplemental bill, and Consolidated Appropriations Act, 2023. Discussed S. 4626, Facilitating the Reshoring for Energy Grid Component Manufacturing Act (all provisions). Discussed the importance of hydropower as a source of renewable energy for public power utilities. Discussed H.R. 9300, the Preventing Unnecessary Deaths During Life-Threatening Emergencies Act, to prohibit the shutoff of electric service during extreme weather events (all provisions). Provided feedback on draft legislation, the BIG WIRES Act, to give the Federal Energy Regulatory Commission the authority to require the expansion of transmission facilities for reliability, among other things. Provided feedback on draft legislation, the Energy Independence and Security Act of 2022, to improve the federal permitting process for energy infrastructure, with a specific focus on the transmission provisions and their potential impact on public power utilities (no bill number). Discussed the Department of Energys reorganization. Provided feedback on draft legislation (all parts), the Enhancing Electric Grid Resilience Act (no bill number). Discussed efforts to improve and strengthen the Low Income Home Energy Assistance Program. Discussed implementation of the Infrastructure Investment and Jobs Act (P.L. 117-58) and how public power utilities may benefit from the cybersecurity, grid resilience, broadband, energy efficiency, and electric vehicle provisions, as well as the research, development, and demonstration programs at the Department of Energy for energy technologies.
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2022 · third_quarter · Q3
Discussed public powers support for legislation to address climate change, including potential legislation to create a clean energy standard and what such legislation would need to include to ensure electricity remains affordable, reliable, and sustainable. Discussed what public power utilities are doing to reduce their greenhouse gas (GHG) emissions. Discussed potential GHG regulations on the power sector under section 111 of the Clean Air Act. Discussed the Environmental Protection Agency's (EPA) proceeding, GHG Emission Guidelines for Existing Sources (RIN 2060-AV10); specifically discussed concerns with coordination of suite of rules impacting the power sector. Also discussed how the direct pay provisions in the Inflation Reduction Act will help public power utilities invest in renewable technologies needed to reduce greenhouse gas emissions. Discussed EPA's proceeding, GHG New Source Performance Standards (2060-AV09); specifically discussed the need for regulatory flexibility to meet new source limits. Also discussed investments in new types of generation technology, such as reciprocating internal combustion engines. Discussed EPA's proceeding, Ozone Federal Implementation Plan (2040-AV51); specifically discussed concerns the proposal could have on bulk power system reliability given the lack of compliance flexibility. Also discussed the cost of emissions allowances. Discussed the need for permitting reform to enable the siting and construction of energy infrastructure. Discussed the Clean Water Act provisions (subtitle B) in the Energy Independence and Security Act of 2022 (no bill number). Provided feedback on S.J. Res 55, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Council on Environmental Quality relating to National Environmental Policy Act Implementing Regulations Revisions. Discussed the potential impacts EPAs changes to the coal combustion residuals rule could have on public power utilities. Discussed legislative efforts to address environmental justice issues (no specific bills). Discussed the regulatory uncertainty created by changing rules on Waters of the United States (WOTUS), specifically on the waste treatment exclusion. Discussed revisions to WOTUS (RIN 2040-AG19), including maintaining the waste treatment exclusion. Discussed Steam Electric Effluent Limitation Guidelines (RIN 2040-AG23), including concerns with spending resources to comply with 2020 ELG rule when EPA anticipates changing the requirements before full implementation of 2020 ELG rule can occur. Also discussed setting wastewater discharge requirements for FGD wastewater based on membrane technology.
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2022 · second_quarter · Q2
Discussed grid security issues, including implementation of the mandatory cyber incident reporting legislation (included in the Consolidated Appropriations Act, 2022 (H.R. 2471)) by the Department of Homeland Securitys Cybersecurity and Infrastructure Security Administration (DHS CISA) and the need to avoid duplicative or conflicting reporting requirements. Discussed the need for DHS CISA to undertake a careful and deliberative implementation process that takes into account existing reporting mandates and to appropriately tailor reporting mandates commensurate with risk to national security. Discussed the importance of protecting the role of the Department of Energy (DOE) as the energy sectors risk management agency. Discussed H.R. 8053, the Guaranteeing Resilient Installations for Defense Act (GRID Act). Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed support for DOE temporarily waiving distribution transformer energy efficiency standards to help spread raw steel materials and increase production volumes. Discussed the strategic transformer reserve provision in section 20301 of H.R. 4521, the America COMPETES Act of 2022. Discussed support for amending section 4251 of S. 1260, the U.S. Innovation and Competition Act of 2021, to ensure that DHS works with DOE in the event of a declaration of a significant incident and to direct DHS and DOE to clarify how a significant incident declaration could impact/interact with the declaration of a grid security emergency. Discussed announcement by the Biden Administration on the Made-in-America Federal Clean Energy Procurement Program. Discussed opposition to the creation of a new must-consider requirement under the Public Utility Regulatory Policies Act of 1978 in H.R. 4521, the America Competes Act. Discussed concerns with a draft letter to FERC on demand charges for electric vehicle (EV) chargers. Discussed electric utilities role in EV charger deployment, including the ability for the electric industry to handle new demand and the importance of working with utilities to right-size projects. Provided feedback on draft legislation on electric school buses and vehicle-to-grid charging technology. Discussed upcoming federal guidance for the National Electric Vehicle Infrastructure (NEVI) formula funding program and public power EV efforts. Discussed the importance of hydropower as an electricity resource for public power utilities and support for modernizing the hydropower licensing and relicensing process. Discussed the Uncommon Dialogue effort to improve the licensing and relicensing process for hydroelectric facilities. Discussed the need for the reliable delivery of natural gas for electricity generation. Discussed possible amendment to the Natural Gas Act to allow for natural gas price emergency declaration. Discussed DOEs Implementation of the DOE National Transmission Planning Study (part of the Infrastructure Investment and Jobs Act), including the importance of having a public power representative and nominating a member to serve on the Study Technical Review Committee Modeling Subcommittee. Discussed transmission issues, including inter-regional transmission planning, cost allocation, siting, and permitting. Also discussed rising transmission costs for public power utilities and the need for joint ownership of transmission by public power utilities. In addition, discussed issues with the interconnection queue in certain regional transmission markets. Discussed the Federal Energy Regulatory Commission (FERC) Notice of Proposed Rulemaking on Transmission (RM-21-17). Discussed S. 3879, the CHARGE Act. Discussed the October Technical Conference on Transmission Planning and Cost Management (AD 22-8). Discussed the impact of MISO capacity auction results on public power utilities.
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2022 · first_quarter · Q1
Discussed the development of the upcoming 2022 Water Resources Development Act (WRDA) (no bill number); also discussed potential Buy America provisions in the bill. Discussed the importance of the Power Marketing Administrations/Army Corps of Engineers hydropower program for public power utilities and the electric grid. Discussed support for the Power Marketing Administrations and the need to protect their statutory mission. Discussed the importance of hydropower (federal and non-federal) and the need for licensing reform. Discussed S. 3719, the Southwestern Power Administration Fund Establishment Act (all provisions). Discussed federal hydropower issues, including the impact of drought on hydropower production from federal dams; markets; rates; and finances. Discussed the Western drought situation and the associated operational and financial challenges it poses to preference power. Discussed the anticipated increased costs to federal hydropower customers resulting from supplemental provided to the Army Corps of Engineers in H.R. 3684, the Infrastructure Investment and Jobs Act and from H.R. 3237, the Emergency Security Supplemental Appropriations Act - and how to fix it in the upcoming WRDA (no bill number, no draft). Discussed the problem of rising joint costs assigned by the Army Corps of Engineers to the Power Marketing Administrations and federal hydropower customers. Discussed the need to modernize the Columbia River Treaty (focus on hydropower).
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2021 · fourth_quarter · Q4
Discussed public powers concerns with the Clean Electricity Performance Program (CEPP) included in H.R. 5376, the Build Back Better Act, to require electric utilities to increase their percentage of clean electricity and the likely inability of many public power utilities to meet the annual compliance obligations. Discussed public powers support for legislation to address climate change, including potential legislation to create a clean energy standard and what such legislation would need to include to ensure electricity remains affordable, reliable, and sustainable. Discussed what public power utilities are doing to reduce their greenhouse gas (GHG) emissions. Discussed the need for the federal government to provide robust support for research, development, and demonstration of technologies needed to reduce GHG emissions. Discussed Environmental Protection Agency (EPA) docket EPA-HQ-OW-2021-0602) on the Revised Definition of Waters of the United States - Rule 1 and its potential impact on public power utilities.
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2021 · third_quarter · Q3
Discussed H.R. 5192, the Clean Hydrogen Production and Investment Tax Credit Act, and the need to ensure it is available to public power utilities as a refundable, direct payment tax credit. Discussed concerns with the possible inclusion of language in the draft Infrastructure Investment and Jobs Act, to incentivize the privatization of public assets. Discussed H.R. 4720/S. 2475, the Energy Sector Innovation Tax Credit - provisions related to the transfer of credits by certain public entities. Discussed the need for comparable incentives for various energy-related tax credits for public power utilities. Discussed S. 292, the Clean Energy for America Act, and H.R. 848, the Growing Renewable Energy and Efficiency Now (GREEN) Act of 2021 - provisions relating to direct payment bonds and refundable direct payment tax credit for public power utilities. Also discussed the EV tax credit provisions and the definition of public power. Discussed support for an amendment to S. 2118, the Clean Energy for America Act, on tax credits for hydropower. Provided feedback and support for technical changes to S. 2306, the Maintaining and Enhancing River Restoration Act of 2021. Discussed tax-related provisions in the House Ways & Means Committee portion of the Build Back Better Act (eventually H.R. 5376) on providing Rural Utility Service loans and grants for renewable energy generation and retirement of debt related to fossil-fuel generation; providing refundable direct payment energy-related tax credits; reinstatement of advance refunding bonds; and increasing the small-issuer exception. Discuss the proposed investment tax credit for transmission. Discussed the need to restore advance refunding bonds and support for H.R. 2288, the Investing in Our Communities Act, and S. 479, the LOCAL Infrastructure Act. Discussed the need to increase the small-issuer exception. Discussed support for H.R. 2634, the Local Infrastructure Financing Tools Act (provision to increase the small-issuer exception). Discussed the need to ease certain private-use restrictions on municipal bonds. Discussed concerns with the sequestration of direct payment bonds, including Build America Bonds. Discussed Treasury guidance related to the taxation of household assistance provided by the Coronavirus State and Local Fiscal Recovery Funds (Pub. Law 117-2, the American Rescue Plan Act).
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2021 · second_quarter · Q2
Discussed H.R. 7516, the Clean Energy Innovation and Deployment Act, all provisions, from the 116th Congress. Discussed and provided feedback on H.R. 1512, the CLEAN Future Act, provisions in Titles II and IV. Discussed climate policy, including APPAs support for federal legislation to address the issue. Discussed potential climate-related provisions that could be included in infrastructure legislation, including a clean energy standard. Discussed what public power utilities are doing to reduce their greenhouse gas (GHG) emissions. Discussed the need for the federal government to provide robust support for research, development, and demonstration of technologies needed to reduce GHG emissions. Discussed the Council on Environmental Qualitys (CEQ) National Environmental Policy Act (NEPA) regulatory amendments. Discussed the importance of modernizing NEPA to facilitate the Biden Administration's infrastructure goals and the historical permitting delays, which have added costs to certain projects.
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2021 · first_quarter · Q1
Discussed draft legislation to protect the supply chain of certain electric grid components. Discussed concerns with potential efforts to impose additional mandatory reporting requirements on electric utilities regarding grid security. Discussed the need for federal funding for public power utilities serving defense critical facilities (i.e., those with defense critical electric infrastructure). Discussed support for language to prevent public disclosure of sensitive critical energy/electric infrastructure information in potential grid security bills. Provided feedback on S. 622, the American Jobs in Energy Manufacturing Act of 2021. Discussed the electric utility industry's efforts to protect the grid and its close work with the federal government on cyber and physical security through the Electricity Subsector Coordinating Council. Discussed APPAs cooperative agreement with the Department of Energy (DE-OE-0000811), Improving the Cyber Resiliency and Security Posture of Public Power, and how APPA used the funding to work with its members to improve their cyber hygiene. Discussed APPAs cooperative agreement with the Department of Energy (DE-CR0000007) and how APPA will use funding to help its members develop and deploy active cyber defense on public power operational technology networks. Discussed SolarWinds supply chain compromise. Discussed Executive Order on the Bulk Power System (EO 13920). Discussed APPAs work with the Department of Energy on mutual aid during national emergencies. Discussed COVID-19 vaccine prioritization for electric utility workers. Discussed future coordination with the Department of Energy on grid security issues. Discussed the impact of COVID-19 on public power utilities and how they were dealing with the pandemic from an operational standpoint; discussed what public power utilities are doing on customer shutoffs during the pandemic; discussed draft language to establish a federal moratorium on utility shutoffs; and discussed support for additional funding for the Low Income Home Energy Assistance Program (LIHEAP) in H.R. 1319, the American Rescue Plan Act. Discussed implementation of the Emergency Renters Assistance Program created by the Consolidated Appropriations Act, 2021 (Pub. Law 116-260). Discussed implementation of Community Development Block Grants - CARES Act - funding for assisting utility customers impacted by the COVID-19 pandemic (Pub. Law 116-136). Discussed provisions to extend mandatory paid sick leave and family medical leave payroll tax credits to governmental entities, provisions to provide LIHEAP to renters, and use of LIHEAP funds to pay electric customer arrearages in H.R. 1319, the American Rescue Plan Act. Discussed H.R. 786, the Supporting State and Local Leaders Act, to grant state and local governments access to payroll tax credits for paid emergency and family leave. Discussed fiscal year 2022 funding for LIHEAP (no bill). Discussed the potential inclusion of language to provide financial assistance to public power utilities negatively impacted by customer non-payments due to the COVID-19 in H.R. 1319, the American Rescue Plan Act. Discussed draft legislation, the Maintaining Access to Essential Services During COVID Emergency Act of 2021, to aid electric utilities negatively impacted by customer non-payments due to pandemic. Discussed the impacts of Winter Storm Uri on public power utilities and concerns about cost impacts to public power customers. Discussed request to President Biden to use the Natural Gas Policy Act to declare a natural gas supply emergency and to authorize the Secretary of Energy to exercise delegated authority under section 302 of the act to cap the price for purchases of natural gas from producers of natural gas or other persons to the extent authorized under the law. Discussed APPA Light Up Navajo Project to provide electric service to Navajo Nation families by using mutual aid from public power utilities to build the infrastructure needed to provide service. Discussed the need for hydropower licensing and relicensing reform (no bill) and the importance of any climate or energy legislation recognizing hydropower as a zero-emitting, renewable resource. Discussed he need for full funding for money authorized in the Energy Act of 2020 (which was then included in H.R. 133 the Consolidated Appropriations, 2021), to the Department of Energy for research, development, and demonstration of technologies needed to meet net-zero emission reduction goals. Also discussed provisions in the Energy Act of 2020 on grid modernization and electric vehicles. Discussed community solar issues and possible legislation to spur community solar. Also discussed on-bill financing for roof-top solar installations. Discussed potential energy-related provisions that could be included in an infrastructure package, including ones on transmission and promoting clean energy technologies. Provided feedback on draft legislation, the Energy Transitions Act, to support communities impacted by the closure of coal facilities. Discussed the EV MAP Act (H.R. 8807 in the 116th Congress). Provided feedback on the EV Infrastructure Rebate Act. Discussed the role of public power utilities in helping deploy electric vehicle charging infrastructure. Provided feedback on the definition of public power in H.R. 448, the Energy Resilient Communities Act. Discussed concerns with proposed transmission incentives in Federal Energy Regulatory Commission (FERC) Docket No. RM 20-10, Notice of Proposed Rulemaking on Electric Transmission Incentives Policy Under Section 219 of the Federal Power Act. Discussed support for distributed energy resources opt-in in FERC Order 2222 (Docket No. RM 18-09) on Participation of Distributed Energy Resource Aggregations in Markets Operated by Regional Transmission Organizations and Independent System Operators. Discussed concerns about rising transmission costs and federal-state jurisdiction concerns. Discussed the North American Electric Reliability Corporation (NERC) report on distributed energy resources, NERC standards efficiency review, and the E-ISAC. Discussed FERC Supplemental Notice of Technical Conference on Resource Adequacy in the Evolving Electricity Sector (Docket No. 21-10).
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2020 · fourth_quarter · Q4
Expressed support for H.R. 359/S. 2095, the Enhancing Grid Security through Public-Private Partnerships Act. Discussed the electric utility industry's efforts to protect the grid and its close work with the federal government on cyber and physical security through the Electricity Subsector Coordinating Council. Discussed cybersecurity provisions in the Fiscal Year 2021 National Defense Authorization Act (NDAA) (H.R. 6395). Discussed opposition to including language in the final NDAA bill that would require mandatory cyber incident reporting. Discussed grid security coordination between the Department of Energy and Department of Homeland Security. Discussed support for information protection provisions in S. 2094, the Enhancing State Energy Security Planning and Emergency Preparedness Act. Discussed S. 4821, a bill to amend the Homeland Security Act of 2002, to clarify that utility line technicians qualify as emergency response providers. Discussed efforts by the electric utility sector to ensure electric service during the COVID-19 pandemic, including efforts undertaken to protect utility workers, obtain testing for key utility personnel, and the need for personal protective equipment for key utility personnel. Also discussed contact tracing for utilities. Discussed APPAs cooperative agreement with the Department of Energy (DE-CR0000007) and how APPA will use funding to help its members develop and deploy active cyber defense on public power operational technology networks. Discussed federal agency efforts/advisories on ransomware and cybersecurity. Included discussion on SolarWinds. Discussed need for essential utility personnel to get access to COVID-19 vaccine. Discussed public power resiliency efforts. Discussed the impact of COVID-19 on public power utilities and how they were dealing with the pandemic from an operational standpoint; discussed what public power utilities are doing on customer shutoffs during the pandemic; discussed language to establish a federal moratorium on utility shutoffs and prevent the collection of debt included in H.R. 6800, the Health and Economic Recovery Omnibus Emergency Solutions (HEROES) Act and H.R. 925, the HEROES Act. Also discussed need to extend mandatory paid sick leave and family medical leave payroll tax credits to governmental entities. Discussed the creation of a forgivable loan program to assist public power utilities negatively impacted by COVID-19. Discussed priorities for inclusion in coronavirus relief legislation - H.R. 133, the Consolidated Appropriations Act, 2021 - forgivable loan program; increased funding for Low Income Home Energy Assistance Program (LIHEAP); rental assistance program, which can also assist renters with utility bills; extension of deadline for using Coronavirus Relief Funds (and additional money for it); and providing public power utilities with comparable incentives for various energy-related tax credits. Also discussed provisions in the bill to provide funding for rural programs and opposition to efforts include language in the bill to prohibit the Federal Reserve from taking steps to ensure municipal market liquidity. Discussed the use of Coronavirus Relief Funds allocated under the CARES Act (Pub. Law 116-136) for utility customer assistance programs. Also discussed use of Paycheck Protection Program funds to pay utility bills (small businesses and nonprofits). Discussed APPA Light Up Navajo Project to provide electric service to Navajo Nation families by using mutual aid from public power utilities to build the infrastructure needed to provide service. Discussed concerns with the inclusion of language (section 5111) in H.R. 4447, the Clean Economy Jobs and Innovation Act in the Energy Act of 2020 (which was then included in H.R. 133 the Consolidated Appropriations, 2021), to direct the Federal Energy Regulatory Commission (FERC) to undertake a rulemaking on interregional transmission planning. Also discussed support for the inclusion of various energy storage provisions (Subtitle C) in the Energy Act of 2020. Also discussed provisions in the Energy Policy Act on grid modernization and electric vehicles. Discussed support for the inclusion of H.R. 3079, the Energy Savings through Public-Private Partnerships Act of 2019, in the Energy Act of 2020. Provided feedback on draft legislation, the Energy Transitions Act, to support communities impacted by the closure of coal facilities. Discussed H.R. 8626, the Energy Resilient Communities Act. Discussed public power microgrid projects. Discussed H.R. 8807, the EV MAP Act. Discussed FERC Notice of Inquiry in RM 20-19 on Potential Risks to Bulk Electric System.
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2020 · third_quarter · Q3
Discussed support for H.R. 3967, Municipal Bond Market Support Act (all provisions) and H.R. 2772, Investing in Our Communities Act (all provisions), and their inclusion in coronavirus relief legislation or infrastructure legislation - H.R. 2, the Moving Forward Act. Discussed provisions in S. 4203, the American Infrastructure Bond Act, to restore advance refunding bonds. Discussed allowing governmental entities, including public power utilities, to receive employer payroll tax credit for emergency paid sick leave and paid family leave in PL 116-227, the Families First Coronavirus Relief Act. Discussed H.R. 5523, the Energy Sector Innovation Tax Credit - provisions related to transfer of credit by certain public entities. Discussed provisions relating to the transferability and direct payment of energy tax credits to public power utilities in H.R. 7516, the Clean Energy Innovation and Deployment Act of 2020. Discussed H.R. 7734/S. 4290, the Building Businesses Back Act of 2020 - provisions related making business-related tax credits refundable. Discussed of the definition of taxpayer in H.R. 7330, the Growing Renewable Energy and Efficiency Now (GREEN) Act. Discussed draft proposal to allow monetization of all business tax credits (applicability to public power). Discussed draft legislation to create COVID Recovery Bonds - provisions expanding qualified private activity bond use to any energy facility. Discussed draft legislation to provide that certain retail utility contracts do not constitute private business use of tax-exempt bond proceeds. Discussed need for comparable incentives for various energy-related tax credits for public power utilities.
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2020 · second_quarter · Q2
Discussed S. 3688, Energy Infrastructure Protection Act. Discussed the electric utility industry's efforts to protect the grid and its close work with the federal government on cyber and physical security through the Electricity Subsector Coordinating Council. Discussed potential legislation granting utilities limited third-party liability protections during a grid security emergency, including support for such legislation. Discussed support for potential Fischer amendment to the Fiscal Year 2021 National Defense Authorization Act (NDAA) to protect facilities with defense critical electric infrastructure (S. 4049). Discussed support for potential Bacon amendment to the Fiscal Year 2021 NDAA to protect facilities with defense critical electric infrastructure (H.R. 6395). Discussed H.R. 7203, GRID Act of 2020. Discussed S. 3728, Critical Infrastructure Employee Protection Act of 2020. Discussed efforts by the electric utility sector to ensure electric service during the COVID-19 pandemic, including efforts undertaken to protect utility workers, obtain testing for key utility personnel, and the need for personal protective equipment for key utility personnel. Also discussed contract tracing for utilities. Discussed APPAs cooperative agreement with the Department of Energy (DE-OE-0000811), Improving the Cyber Resiliency and Security Posture of Public Power, and how APPA is using funding to work with its members to improve their cyber hygiene. Discussed APPA's cooperative agreement with DOE's Infrastructure Security and Energy Restoration Division -Integrating State Energy Assurance and Federal Energy Emergency Response Initiatives with Local Energy Emergency Response (DE-OE0000757). Discussed Cybersecurity Solarium Commission report. Discussed Executive Order 13920, Securing the United States Bulk-Power System. Discussed H.R. 7410, the Hydropower Clean Energy Future Act. Discussed the impact of COVID-19 on public power utilities and how they were dealing with the pandemic from an operational standpoint; discussed what public power utilities are doing on customer shutoffs during the pandemic; discussed language to establish a federal moratoria on utility shutoffs and prevent the collection of debt included in H.R. 6379, the Taking Responsibility for Families and Worker Act, and H.R. 6800, the Health and Economic Recovery Omnibus Emergency Solutions (HEROS) Act Discussed possible need for direct assistance for public power utilities impacted by COVID-19; discussed public priorities for coronavirus relief package following passage of H.R. 748, the Coronavirus Aid, Relief, and Economic Security Act - direct aid, increased funding for the Low Income Home Energy Assistance Program (LIHEAP) and Coronavirus Relief Funds, and completed implementation of the Municipal Liquidity Facility. Discussed priorities for inclusion in coronavirus relief legislation - direct aid, restoration of advance refunding bonds, increasing the small-issuer exception, increased funding for LIHEAP, making emergency supplemental appropriations for the Power Marketing Administrations non-reimbursable; and providing public power utilities with comparable incentives for various energy-related tax credits. H.R. 6800, the Health and Economic Recovery Omnibus Emergency Solutions (HEROS) Act.
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2020 · first_quarter · Q1
Discussed the Environmental Protection Agency's (EPA) proposed reconsideration of the Waters of the U.S. rule (EPA-HQ-OW-2018-0149). Discussed EPA's proposed Effluent Guideline Limitations Reconsideration rule (EPA-HQ-OW-2009-0819). Discussed what public power utilities are doing to reduce their greenhouse gas emissions and support for policies that would reduce emissions, such as energy efficiency, the promotion of hydropower and nuclear power, and the promotion of electric vehicles. Provided feedback on the Clean Energy Innovation and Deployment Act (draft climate change legislation). Discussed the CLEAN Future Act (draft climate change legislation). Discussed climate policies, such as cap and trade, clean energy standard, and carbon taxes.
Discussed electric vehicles and the deployment of charging infrastructure by public power utilities. Also discussed electric vehicle infrastructure costs, including make-ready costs. Expressed support for S. 674, the Clean Corridors Act of 2019, and its House companion, H.R. 2616. Expressed support for inclusion of the legislation in surface transportation legislation in the House. Discussed support for nuclear power and its importance for addressing climate change. Discussed the issue of spent nuclear fuel.
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2019 · fourth_quarter · Q4
Discussed support for the restoration of advance refunding bonds, H.R. 2772, Investing in Our Communities Act. Discussed possible legislation to reinstate advance refunding bonds. Discussed the need for comparable incentives for public power investments in clean energy and energy storage, including support for S. 1288, the Clean Energy for America Act. Discussed H.R. 2704/S. 3032, the Renewable Energy Transferability Act. Discussed credit transferability in draft version of Energy Sector Innovation Act. Discussed normalization of tax credits. Discussed tax credit refundability in the GREEN Act (draft legislation).
Discussed the exemption in Section 224 of the Communications Act that precludes Federal Communications Commission (FCC) regulation of public power pole attachments. Expressed opposition to any attempt to repeal or weaken the exemption. Discussed public powers concerns with FCC proceeding to open the 6 GHz band to unlicensed users (FCC ET Docket No. 18-295 and GN Docket No. 17-183).
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2019 · third_quarter · Q3
Discussed the need for congressional oversight of the Bureau of Land Managements (BLM) and U.S. Forest Services implementation of the vegetation management provisions included in P.L. 115-141. Discussed support for the Environmental Protection Agency's efforts to rewrite the Waters of the U.S. rule (EPA-HQ-OW-2017-0203). Discussed the regulation of coal combustion residuals. Discussed support for common sense reform of the Endangered Species Act.
Discussed what public power utilities are doing to reduce their greenhouse gas emissions and support for policies that would reduce emissions, such as energy efficiency, the promotion of hydropower and nuclear power, and the promotion of electric vehicles. Discussed the Delisting Petition for Stationary Combustion Turbines at the Environmental Protection Agency (EPA-HQ-OAR-2017-0688).
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2019 · second_quarter · Q2
Discussed support for the restoration of advance refunding bonds, H.R. 2772, Investing in Our Communities Act. Discussed support for ending the sequestration of Build America Bonds. Discussed the need for comparable incentives for public power investments in clean energy and energy storage, including support for S. 1288, the Clean Energy for America Act. Discussed the need to increase the small-issuer exemption to $30M. Discussed the need to simplify private-use rules for municipal bonds. Discussed the importance of tax-exempt financing for public power infrastructure investments. Provided feedback on draft legislation to provide transferability of accumulated energy tax credits. Discussed H.R. 2704, Renewable Energy Transferability Act. Provided feedback on S. 1142, Energy Storage Tax Incentive and Deployment Act of 2019.
Lobbied in support of repealing and replacing of Section 433 of Energy Independence and Security Act -- S. 1245/H.R. 2664. Discussed efforts by public power utilities to promote energy efficiency. Discussed electric vehicles and the development of charging infrastructure by public power utilities. Expressed support for S. 674, the Clean Corridors Act of 2019, and the inclusion of similar language in an infrastructure bill. Lobbied on the need for a permanent repository for spent nuclear waste. Discussed the importance of small modular reactors and the development of new nuclear to help address climate change. Discussed H.R. 3136, Storage and Transportation of Residual and Excess Nuclear Fuel Act of 2019. Provided feedback on draft legislation to provide federally subsidized loans to utilities offering home energy efficiency loans to customers.
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2019 · first_quarter · Q1
Discussed support for the restoration of advance refunding bonds, including draft legislation to do so. Discussed support for ending the sequestration of Build America Bonds. Discussed the need for comparable incentives for public power investments in clean energy and energy storage. Discussed the need to increase the small-issuer exemption to $30M. Discussed the need to simplify private-use rules for municipal bonds. Discussed the importance of tax-exempt financing for public power infrastructure investments.
Discussed what public power utilities are doing to reduce their greenhouse gas emissions and support for policies that would reduce emissions, such as energy efficiency, the promotion of hydropower and nuclear power, and the promotion of electric vehicles. Expressed support for reexamining the Waters of the U.S. Rule finalized by the Environmental Protection Agency and U.S. Army Corps of Engineers.
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2018 · fourth_quarter · Q4
Provided feedback on and support for H.R. 5240, the Enhancing Grid Through Public-Private Partnerships Act, to permanently authorize program assisting small- and medium-sized electric utilities with grid security. Discussed the electric utility industry's efforts to protect the grid and its close work with the federal government on cybersecurity. Discussed support for legislation to improve the hydropower licensing and relicensing reform process -- H.R. 3043 and provisions in S. 1460. Discussed language in H.R. 723/S. 239 that carves out federal hydropower facilities from the definition of eligible federal facilities that can use energy savings performance contracts. Lobbied in support of wholesale electricity market reforms with focus on capacity markets and protecting customer interests, as well as ensuring public power's right to self-supply. Discussed concerns with any proposed attempts by Congress to federalize rate design and how public power is working with its customers to enable distributed energy resources. Discussed implementation of vegetation management legislation now enacted into law, P.L. 115-141, by the U.S. Forest Service and Bureau of Land Management. Provided feedback on S. 1875, the Flexible Grid Interstate Act of 2017. Expressed concerns with the provisions on model standards. Met with FERC on reliability issues and discussed RM 19-10. Met with FERC on generator interconnection policies in Midcontinent ISO.
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2018 · third_quarter · Q3
Provided feedback on and support for H.R. 5240, Enhancing Grid Through Public-Private Partnerships Act, to permanently authorize program assisting small- and medium-sized electric utilities with grid security. Provided feedback on H.R. 5239, Cyber Sense Act of 2018, to establish a volunteer program that identifies and promotes cyber-secure products intended for use in the bulk power system. Discussed the need for enhanced background screening of utility employees and provided feedback on draft legislation. Supported legislation to establish the new Office of Cybersecurity, Energy Security, and Emergency Response (CESER) at the Department of Energy -- H.R. 5174, Energy Emergency Leadership Act. Discussed the electric utility industry's efforts to protect the grid and its close work with the federal government on cybersecurity. Discussed support for legislation to improve the hydropower licensing and relicensing reform process -- H.R. 3043 and provisions in S. 1460. Expressed support for S. 724, a bill to amend the Federal Power Act to modernize authorizations for necessary hydropower approvals. Discussed language in H.R. 723/S. 239 that carves out federal hydropower facilities from the definition of eligible federal facilities that can use energy savings performance contracts. Lobbied in support of wholesale electricity market reforms with focus on capacity markets and protecting customer interests, as well as ensuring public power's right to self-supply. Discussed concerns with any proposed attempts by Congress to federalize rate design and how public power is working with its customers to enable distributed energy resources. Discussed concerns with wholesale markets and Federal Energy Regulatory Commission (FERC) intrusion into energy matters that fall within state/local jurisdiction under the Federal Power Act. Lobbied on the need to protect public power and consumer interests in the potential expansion of the California ISO. Discussed implementation of vegetation management legislation, H.R. 1873, included in H.R. 1625, the Consolidated Appropriations Act, 2018, by the U.S. Forest Service and Bureau of Land Management. Lobbied in support of H.R. 587/S. 186, the FAIR Rates Act. Discussed FERC's ongoing review of form 715 submission requirements.
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2018 · second_quarter · Q2
Discussed the tax-exempt financing of public power infrastructure investments. Lobbied in support of H.R. 5003 to restore advance refunding bonds. Discussed potential ways to change private use restrictions on municipal bonds. Discussed amendment #98 to H.R. 4, the FAA Reauthorization Act, regarding the use of tax-exempt municipal bonds to finance private operation of schools, police stations, courthouses, and other public buildings.
Lobbied to preserve the municipal exemption in Section 224 of the Communications Act from federal pole attachment regulations. Expressed opposition to the Thune-Schatz draft bill that would essentially gut public power's exemption from federal pole attachment regulations. Discussed concerns with proposed rules and notices of inquiry issued by the Federal Communications Commission on wireline and wireless broadband deployment. FCC No. 17-79, 17-84.
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2018 · first_quarter · Q1
Lobbied to preserve the municipal exemption in Section 224 of the Communications Act from federal pole attachment regulations. Discussed concerns with proposed rules and notices of inquiry issued by the Federal Communications Commission on wireline and wireless broadband deployment. FCC No. 17-79, 17-84
Lobbied in support of wholesale electricity market reforms with focus on capacity markets and protecting customer interests. Lobbied on the need to protect public power and consumer interests in the potential expansion of the California ISO. Discussed FERC's order on grid resiliency -- FERC RM 18-1. Provided feedback on and support for H.R. 5240, Enhancing Grid Through Public-Private Partnerships Act, to permanently authorize program assisting small- and medium-sized electric utilities with grid security. Provided feedback on H.R. 5239, Cyber Sense Act of 2018, to establish a volunteer program that identifies and promotes cyber-secure product intended for use in the bulk power system. Discussed the need for enhanced background screening of utility employees and provided feedback on draft legislation. Discussed support for legislation to improve the hydropower licensing and relicensing reform -- H.R. 3043 and provisions in S. 1460. Discussed language in H.R. 723/S. 239 that carves out federal hydropower facilities from the definition of eligible federal facilities that can use energy savings performance contracts. Discussed support for vegetation management legislation, H.R. 1873, and its inclusion in H.R. 1625, the Consolidated Appropriations Act, 2018. Lobbied in support of congressional oversight of the implementation of the Federal Power Act. Discussed FERC policies on distributed energy resources -- FERC RM 16-23. Discussed FERC policies on supply chain cybersecurity -- FERC RM 17-13. Discussed FERC policies on price formation -- FERC RM 17-03; 17-20. Discussed concerns with release of Critical Electric Infrastructure Information -- FERC Form 715. Discussed views on FERC policies on capacity markets. Discussed support for needed reforms to the Public Utility Regulatory Policies Act of 1978 and support for H.R. 4476, the PURPA Modernization Act. Lobbied in support of H.R. 587, the Fair RATES Act, to amend the Federal Power Act to permit a party to seek a rehearing and subsequent judicial review of any rate change by a public utility that takes effect without FERC issuing an order making such change effective. Provided feedback on proposed changes at the Department of Energy to the PMA reporting structure.
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2017 · fourth_quarter · Q4
Lobbied in support of wholesale electricity market reforms with focus on capacity markets and protecting customer interests. Lobbied on the need to protect public power and consumer interests in the potential expansion of the California ISO. Discussed Dept. of Energy's Notice of Proposed Rulemaking on grid resiliency -- FERC RM 18-1. Discussed the importance of the electric utility industry and government partnership to share information and work together on grid security. Provided feedback on proposed legislation permanently authorizing program assisting small- and medium-sized utilities with grid security. Discussed the need for enhanced background screening of utility employees and provided feedback on draft legislation. Discussed need for legislation to improve the hydropower licensing and relicensing reform -- H.R. 3043 and provisions in S. 1460. Discussed views on bills to support closed loop pumped storage and addition of generation at non-powered dams -- H.R. 2880 and H.R. 2872. Discussed language in H.R. 723/S. 239 that carves out federal hydropower facilities from the definition of eligible federal facilities that can use energy savings performance contracts. Discussed potential for including legislation to improve interstate natural gas pipeline permitting process, such as H.R. 2910 and provisions in S. 1460, in infrastructure legislation. Discussed need for legislation on vegetation management and in support of H.R. 1873. Also support vegetation management language in S. 1460, Energy & Natural Resources Act of 2017. Lobbied in support of congressional oversight of the implementation of the Federal Power Act. Discussed issues related to distributed generation, including rate design and microgrids. Provided feedback on draft bills to promote distributed energy resources. Also provided feedback on S. 1874, Distributed Energy Demonstration Act of 2017, S. 1875, the Flexible Grid Infrastructure Act of 2017, and S. 1876, Reducing the Cost of Energy Storage Act of 2017. Discussed FERC policies on distributed energy resources -- FERC RM 16-23. Discussed FERC policies on accommodating resource policies -- FERC AD 17-11. Discussed FERC policies on Public Utility Regulatory Policies Act -- FERC AD 16-16. Discussed FERC policies on price formation -- FERC RM 17-03; RM 17-20 Discussed needed reforms to the Public Utility Regulatory Policies Act of 1978 and provided feedback on H.R. 4476.
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2017 · third_quarter · Q3
Lobbied to preserve the municipal exemption in Section 224 of the Communications Act from federal pole attachment regulations. Discussed concerns with proposed rules and notices of inquiry issued by the Federal Communications Commission on wireline and wireless broadband deployment. FCC No. 17-79, 17-84
Lobbied in support of funding for Cybersecurity for Energy Delivery Systems program at the Department of Energy. Discussed opposition to fiscal year 2018 budget proposal from President that recommends selling the transmission assets of the Power Marketing Administrations. Supported H.Con. Res 71 that opposes the sale of Power Marketing Administration transmission assets proposed in President's FY 2018 budget. Lobbied in support of Power Marketing Administrations and TVA. Also discussed issues specific to the Western Area Power Administration. Expressed support for Presidential Granting of 100 percent reimbursement for category A and B costs for Puerto Rico in the aftermath of Hurricane Maria -- FEMA cost sharing for Notice of Major Disaster for the Commonwealth of PR (FEMA 4339-DR)
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2017 · second_quarter · Q2
Lobbied in support of H.R. 806, the Ozone Standards Implementation Act. Lobbied in support of Clean Air Act reform. Discussed the regulation of carbon dioxide emissions from fossil fuel-fired power plants.
Lobbied in support of wholesale electricity market reforms with focus on capacity markets and protecting customer interests. Lobbied on the need to protect public power and consumer interests in the potential expansion of the California ISO. Lobbied in support of FAIR Rates Act (H.R. 238). Discussed the importance of the electric utility industry and government partnership to share information and work together on grid security; discussed regulations on grid security; discussed industry efforts on the potential threat of electromagnetic pulse to the electric grid. Discussed need for legislation to improve the hydropower licensing and relicensing reform, including support for H.R. 3043. Discussed need for legislation to improve interstate natural gas pipeline permitting process, including support for H.R. 2910. Discussed need for legislation on vegetation management and in support of H.R. 1873. Lobbied in support of congressional oversight of the implementation of the Federal Power Act. Discussed issues related to distributed generation, including rate design and microgrids. Provided feedback on draft bills to promote distributed energy resources. Discussed the need for enhanced background screening of utility employees. Discussed language in H.R. 723/S. 239 that carves out federal hydropower facilities from the definition of eligible federal facilities that can use energy savings performance contracts. Discussed H.R. 3050 on state energy security planning and provided feedback on it. Discussed needed reforms to the Public Utility Regulatory Policies Act of 1978. Discussed issues being examined in DOE study on grid reliability, including wholesale markets, renewables, and hydropower.
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2017 · first_quarter · Q1
Lobbied in support of Endangered Species Act reform.
Lobbied in support of wholesale electricity market reforms with focus on capacity markets and protecting customer interests. Lobbied on the need to protect public power and consumer interests in the potential expansion of the California ISO. Lobbied in support of FAIR Rates Act (H.R. 238). Discussed views on cybersecurity recommendations in the Quadrennial Energy Review 1.2. Lobbied on S. 79 to establish pilot program to examine whether to add manual controls on electric grid. Discussed Electric Power Research Institute report on electromagnetic pulse. Lobbied on S. 529, bill to require the Department of Energy to get approval from state public utility commission and governor before exercising eminent domain to acquire property for S. 1222 transmission lines. Discussed need for legislation to improve the hydropower licensing and relicensing reform. Discussed need for legislation to improve interstate natural gas pipeline permitting process. Discussed need for legislation on vegetation management and in support of H.R. 1873. Lobbied in support of congressional oversight of the implementation of the Federal Power Act. Discussed issues related to distributed generation, including rate design and microgrids. Discussed APPA's comments on Federal Energy Regulatory Commission proceeding on energy storage. Discussed transmission policy. Discussed the importance of the electric utility industry and government partnership to share information and work together on grid security. Discussed bulk power system reliability, including compliance with NERC standards.
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2016 · fourth_quarter · Q4
Expressed support for efforts to update the Endangered Species Act. Expressed support for coal ash language in S. 612, the Water Infrastructure Improvements for the Nation Act.
Supported the continued use of tax-exempt financing for municipal/public power purposes. Lobbied in support of H.R. 5879 regarding the advanced nuclear production tax credit. Lobbied on tax reform efforts.
Discussed issues of importance to public power in S. 2012, the Energy Policy Modernization Act of 2016 (House and Senate versions), including provisions on capacity markets, grid security, grid modernization, distributed generation, energy efficiency, hydropower licensing reform, pipeline permitting, reliability, vegetation management, and geomagnetic disturbances/electromagnetic pulses. Discussed issues surrounding distributed generation and concerns with attempts to federalize what is a state/local jurisdictional issue. Expressed concerns about regional transmission organizations markets, including a proposed energy imbalance market and existing mandatory capacity markets. Encouraged oversight of FERC more generally and how the Federal Power Act is being implemented. Lobbied in support of protecting consumers interests in regional transmission organizations and independent system operator markets. Discussed implications of the expansion of the California ISO in the West for public power utilities. Lobbied on H.R. 1073/S.1846, preserving the directing NERC-FERC model for grid security regulations. Lobbied on S. 3017 -- cybersecurity provision directing DNI and DHS to provide voluntary assistance from the intelligence community to certain critical infrastructure owners/operators. Supported oversight efforts on Federal Power Act.
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2016 · third_quarter · Q3
Discussed the potential impact of the final Clean Power Plan on public power.
Supported the continued use of tax-exempt financing for municipal/public power purposes, and opposed provisions and legislation to tax municipal bonds. Lobbied in support of H.R. 5879 regarding the advanced nuclear production tax credit. Lobbied on tax reform efforts. Discussed the need for clarification of the solar residential tax credit (IRC Section 25D).
Supported bills to ensure regulatory relief for hydro facilities. Supported language in the House and Senate energy bills to streamline hydro and relicensing for all sites of hydro facilities. Discussed the issue of mandatory conditioning during the hydropower licensing/relicensing process. Discussed the impact of language in H.R. 5303/S. 3040 regarding changes to reservoir operation manuals and allocation of costs at federal hydropower facilities.
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2016 · second_quarter · Q2
Expressed concerns with provisions in draft broadband infrastructure bill regarding pole attachment and their potential impact on public power.
Supported the continued use of tax-exempt financing for municipal/public power purposes, and opposed provisions and legislation to tax municipal bonds. Lobbied in support of including a fix to the nuclear production tax credit in the tax title of the Federal Aviation Administration (FAA) bill -- H.R. 4441, Aviation Innovation, Reform, and Reauthorization Act/S. 2658 -- FAA Reauthorization. Also lobbied on the need to fix the nuclear production tax credit outside of FAA legislation. Lobbied on potential impact of Internal Revenue Service proposed regulation on the definition of political subdivision (Reg-129067-15.
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2016 · first_quarter · Q1
Discussed the need to monitor implementation of S. 808, the Surface Transportation Board Re-authorization Act of 2015. Monitored S. 853, the Rail Shipper Fairness Act of 2015.
Expressed support for efforts to update the Endangered Species Act. Supported legislation (S. 2446, Improving Coal Combustion Residuals Regulation Act of 2016). Advocated in support of H.R. 2576 and S. 697 to update the Toxic Substance Control Act.
Supported the continued use of tax-exempt financing for municipal/public power purposes, and opposed provisions and legislation to tax municipal bonds. Monitored impacts of sequestration on Build America Bonds (BABs). Advocated on H.R. 2209, to require the federal bonding agencies to treat municipal bonds as high quality liquid assets.
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2015 · fourth_quarter · Q4
Monitored pole attachment rate issue and educated House and Senate staff on this issue.
Expressed strong concerns about EPA's proposed Clean Power Plan and the impact on public power. Relayed our concerns about docket EPA-HQ-OAR-2013-0602. Also, discussed our concerns regarding ozone NAAQS rules. Opposed to EPA's proposed Waters of the U.S. rule under the Clean Water Act. Supported S.J. Res. 23, S.J. Res. 24, H.J. Res. 71, and H.J. Res. 72, disapproval resolutions on EPA rules to regulate carbon dioxide emissions from new and existing plants. Supported S. 1140, the Federal Water Quality Protection Act. Supported H.R. 2042, the Ratepayer Protection Act, and companion legislation S. 1324, the Affordable Reliable Electricity Now Act of 2015.
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2015 · third_quarter · Q3
Monitored pole attachment rate issue. Supported municipal broadband deployment, and educated House and Senate staff these issues.
Supported bills to ensure regulatory relief for small hydro facilities. Supported legislation in the House and Senate energy bill development to streamline hydro and relicensing for all sites of hydro facilities. Supported a hydro amendment in H.R.8, the North American Energy Security and Infrastructure Act of 2015, to introduce provisions for hydro relicensing reform to the bill. Monitored agency implementation of hydro bills that passed in the 113th Congress (H.R. 678, H.R. 267) Monitored Nuclear Regulatory Commission (NRC) and nuclear waste issues (S. 854: Nuclear Waste Administration Act of 2015). Monitored issues involving the export of natural gas (liquefied natural gas or LNG).
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2015 · second_quarter · Q2
Support removal of the antitrust exemptions for the railroads, and support reforms at the Surface Transportation Board in order to ensure that rail customers are not the subject of monopoly shipping rates. Monitored S. 808 STB Re authorization Act of 2015, which passed the Senate without amendment.
Support legislation (H.R. 1734, the Improving Coal Combustion Residuals Regulation Act of 2015) re: EPA regulation of coal ash as a non-hazardous waste, which passed the House Energy and Commerce Committee on April 15. Opposed to EPA proposed Clean Power Plan and briefed House and Senate staff on financial impacts of the proposed rule. Discussed concept of reliability safety valve for proposed rules that will impact grid reliability. Opposed to EPA's proposed Waters of the U.S. rule under the Clean Water Act. Expressed support for H.R. 2042 Ratepayer Protection Act. Expressed concerns about S. 1324, the Affordable Reliable Electricity Now Act of 2015.
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2015 · first_quarter · Q1
Monitored the issue of "retransmission consent" with regard to access to cable programming. Also monitored the issues of program access and video competition. Monitored pole attachment rate issue. Support municipal broadband deployment, and educated House and Senate staff these issues as they begin to the House Telecommunications Subcommittee begins rewrite the Telecommunications Act of 1996.
Support legislation (H.R. 1734, the Improving Coal Combustion Residuals Regulation Act of 2015) re: EPA regulation of coal ash as a non-hazardous waste. Opposed to EPA proposed Clean Power Plan and briefed House and Senate staff on financial impacts of the proposed rule. Discussed concept of reliability safety valve for proposed rules that will impact grid reliability. Opposed to EPA's proposed Waters of the U.S. rule under the Clean Water Act.
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2014 · fourth_quarter · Q4
Monitored the issue of "retransmission consent" with regard to access to cable programming. Also monitored the issues of program access and video competition. Monitored pole attachment rate issue. Support municipal broadband deployment, and educated House Telecommunications Subcommittee on these issues as they begin to rewrite the Telecommunications Act of 1996.
Expressed concerns about or opposition to markets issues related to regional transmission organizations, including proposed energy imbalance market and existing mandatory capacity markets. Encouraged oversight of FERC more generally. Monitored issues related to electric vehicles, particularly regarding funding issues. Continued support of revised Senergy efficiency bill, S. 1392. Discussed potential legislation to ensure that federal agencies take electric reliability into consideration when developing regulations.Worked to ensure small utilities that are defined as small businesses under SBREFA get appropriate consideration under any pending and future EPA and FERC regulations. Supported H.R. 2542, which modified the Regulatory Flexibility Act and passed the House. Supported Senator Klobuchar bill related to preventing copper theft. Supported H.R. 1199 to delete Section 433 of EISA 2007, which mandates that all federal buildings use no fossil fuel by 2030. Also suppored other efforts to fix this issue. Support S. 2620, the Grid Reliability Act of 2014 (companion bill to H.R. 271.) While not a federal issue, discussed issues surrounding distributed generation (namely, rooftop solar) with DOE staff and with some offices on Capitol Hill. Discussed the Quadrennial Energy Review (and its focus on distribution, transmission and storage of energy) with DOE and the White House and submitted statements and other materials related to that process. Discussed the need for enhanced liability protection for electric utilities who are subject to a cybersecurity attack. Briefed Senators and House Members and staff on the physical security of the electric system, and opposed additional legislation resulting in greater regulation. Discussed the issue of the availability of spare transformers with DOE and others. Supported information sharing legislation such as CISPA, H.R. 3523, and the Cybersecurity Information Sharing Act of 2014, S. 2588. Supported cybersecurity related bills S. 2519 and S. 1353. Reviewed and proposed modifications to legislation related to electromagnetic pulses (EMPs) and their impacts on the electric grid -- H.R. 3410. Discussed the "risk-based registration" initiative by the North American Electric Reliability Corporation with the Federal Energy Regulatory Commission. This initiative is aimed at lessening the regulatory burden on smaller utilities.
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2014 · third_quarter · Q3
Support legislation (H.R. 2218) re: EPA regulation of coal ash as a non-hazardous waste. Opposed to EPA's proposed rulemaking on a New Source Performance Standard (NSPS) for greenhouse gases at future fossil-fuel fired power plants, and do not believe CCS adequately demonstrated (EPAOAR-20130495). Opposed to EPA proposed rulemaking on NSPS for existing power plants (EPAHQOAR20130602), and briefed House Science Committee members and staff on state perspectives on the issue.Opposed to EPA's proposed Waters of the U.S. rule under the Clean Water Act (EPA-HW-OW-2011-0880. Supported H.R. 5078, Waters of the United States Regulatory Protection Act, which passed the House.Supported Whitfield-Manchin bill (H.R. 3826) to establish a more rigorous process for EPA to be able to establish NSPS for greenhouse gas emissions. Support H.R. 1900 related to Natural Gas Pipeline Permitting Reform Act. Monitored Water Resources Development Act (WRDA/WRDDA) implementation, with emphasis on U.S. Army Corps of Engineers reform and dam safety.
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2014 · second_quarter · Q2
Support efforts in Congress (including House-passed bill, H.R. 3309) to address abuse of the patent system by patent assertion entities (PAEs), commonly known as patent trolls.
Monitored the issue of "retransmission consent" with regard to access to cable programming. Also monitored the issues of program access and video competition. Monitored pole attachment rate issue. Support municipal broadband deployment, and educated House Telecommunications Subcommittee on these issues as they begin to rewrite the Telecommunications Act of 1996.
Expressed concerns about or opposition to markets issues related to regional transmission organizations, including proposed energy imbalance market and existing mandatory capacity markets (FERC docket # AD 13-7). Encouraged oversight of FERC more generally. Monitored issues related to electric vehicles, particularly regarding funding issues. Support revised Senergy efficiency bill, S. 1392, which failed on the Senate floor.Worked to ensure small utilities that are defined as small businesses under SBREFA get appropriate consideration under any pending and future EPA and FERC regulations, and support H.R. 2542 to modify the Regulatory Flexibility Act. Supported Senator Klobuchar bill related to preventing copper theft. Support H.R. 1199 to delete Section 433 of EISA 2007, which mandates that all federal buildings use no fossil fuel by 2030. Also support other efforts to fix this issue. While not a federal issue, discussed issues surrounded distributed generation (namely, rooftop solar) with DOE staff. Discussed the process surrounding the pending Quadrennial Energy Review (and it's focus on distribution, transmission and storage of energy) with DOE and the White House and submitted statements and other materials related to that process. Discussed the need for enhanced liability protection for electric utilities who are subject to a cyber-security attack. Briefed Senators and House Members and staff on the physical security of the electric system, and opposed additional legislation resulting in greater regulation. Discussed the issue of the availability of spare transformers with DOE and others. Support information sharing legislation such as CISPA, H.R. 3523, and the recently passed Senate Intelligence Committee information sharing bill (no bill number to date). Supported the SMART GRID Study Act, H.R. 2962.
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2014 · first_quarter · Q1
Supported the continued use of tax-exempt financing for municipal/public power purposes, and opposed provisions, like those included in the Administration's FY 2015 budget proposal, to tax municipal bonds. Support H. Res. 112, highlighting the value of tax-exempt financing, and authored by Reps. Terry and Neal. Monitored impacts of sequestration on Build America Bonds (BABs). Supported efforts to reallocate unused Clean Renewable Energy Bonds as part of the tax extenders package considered by SenateFinance Committee.
Supported legislation (H.R. 2218) re: EPA regulation of coal ash as a non-hazardous waste. Expressed concerns about parameters of effluent limitation guidelines under the Clean Water Act, pending at EPA. Concerned about air regulations on power plants being promulgated by EPA, including utility MACT (MATS). Opposed to EPA's proposed rulemaking on NSPS for greenhouse gases at future fossil-fuel fired power plants, and do not believe CCS adequately demonstrated (EPA-OAR-2013-0495), and believe therewill be problems withe wholesale electricity markets as also discussed in that docket. Supported Whitfield-Manchin bill (H.R. 3826) to establish a more rigorous process for EPA to be able to establish NSPS for greenhouse gas emissions. Discussed the electricity/natural gas nexus with Congress, FERC (docket #AD 12-12), EPA. Support H.R. 1900 related to Natural Gas Pipeline Permitting Reform Act. Monitored Water Resources Development Act (WRDA) progress, with emphasis on U.S. Army Corps of Engineers reform and dam safety. Oppose Section 2014 of Senate version of WRDA bill, S. 601. Support House version of WRRDA, H.R. 3080. Want to ensure that final version of WRDA does not impact public power's ability to use tax-exempt financing for hydro projects. Support H.R. 271, Olson reliability bill.
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2013 · fourth_quarter · Q4
Supported the continued use of tax-exempt financing for municipal/public power purposes, and opposed provisions, like those included in the Administration's FY 2014 budget proposal, to tax municipal bonds. Support H. Res. 112, highlighting the value of tax-exempt financing, and authored by Reps. Terry and Neal. Monitored impacts of sequestration on Build America Bonds (BABs).
Supported legislation (H.R. 2218) re: EPA regulation of coal ash as a non-hazardous waste. Expressed concerns about parameters of effluent limitation guidelines under the Clean Water Act, pending at EPA. Concerned about air regulations on power plants being promulgated by EPA, including utility MACT (MATS). Opposed to EPA's proposed rulemaking on NSPS for greenhouse gases at future fossil-fuel fired power plants. Continue to discuss the electricity/natural gas nexus with Congress, FERC, EPA.Support H.R. 1900 related to Natural Gas Pipeline Permitting Reform Act. Monitored Water Resources Development Act (WRDA) progress, with emphasis on U.S. Army Corps of Engineers reform and dam safety. Oppose Section 2014 of Senate version of WRDA bill, S. 601. Support House version of WRRDA, H.R. 3080. Making sure that final version of WRDA does not impact public power's ability to use tax-exempt financing for hydro projects. Support H.R. 271, Olson reliability bill.
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2013 · third_quarter · Q3
Monitored the issue of "retransmission consent" with regard to access to cable programming. Monitored pole attachment rate issue. Support municipal broadband deployment, including in rural areas served by public power.
Expressed concerns about or opposition to markets issues related to regional transmission organizations, including proposed energy imbalance market and existing mandatory capacity markets; supported S. 1353, Senate Commerce Committee cyber bill; monitored development of executive order on cyber security and engaged in NIST process; monitored issues related to electric vehicles, particularly regarding funding issues. Support revised Shaheen-Portman energy efficiency bill, S. 1392, pending on Senate floor.Monitor rulemakings related to transmission policy. Worked to ensure small utilities that are defined as small businesses under SBREFA get appropriate consideration under any pending and future EPA and FERC regulations, and support H.R. 2542 to modify the Regulatory Flexibility Act. Supported Senator Klobuchar bill related to preventing copper theft. Support H.R. 1199 to delete Section 433 of EISA 2007, which mandates that all federal buildings use no fossil fuel by 2030. Also support other efforts to fix this issue. Expressed concerns at the Energy Information Administration related to a newly proposed data collection form -- EIA-930 -- that would collect load (demand) and interchange data from balancing authorities on an hourly basis. Provided questions related to FERC activities as part of Ron Binz confirmation process. Did not take position on Binz nomination itself (do not take positions on Administration Executive Branch nominees).
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2013 · second_quarter · Q2
Monitored smart grid programs and their intersection with the telecommunications industry, and responded to requests for meetings and information on the subject to DOE. Supported the need to allow electric utilities to access spectrum for wireless; monitored implementation of S. 911 at NTIA. Monitored the issue of "retransmission consent" with regard to access to cable programming. Monitored pole attachment rate issue. Support municipal broadband deployment, including in rural areas served by public power.
Supported the continued use of tax-exempt financing for municipal/public power purposes, and opposed provisions, like those included in the Administration's FY 2014 budget proposal, to tax municipal bonds. Support H. Res. 112, highlighting the value of tax-exempt financing, and authored by Reps. Terry and Neal. Supported "Dear Colleague" letter authored by Reps. Ruppersburger & Hultgren expressing support for tax-exempt financing. Monitored impacts of sequestration on Build America Bonds (BABs).
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2013 · first_quarter · Q1
Supported legislation (HR 2273, S. 1751/1971) re: EPA regulation of coal ash as a non-hazardous waste. Expressed concerns about parameters of effluent limitation guidelines under the Clean Water Act, pending at EPA. Concern about air regulations on power plants being promulgated by EPA, including utility MACT (MATS). Monitoring EPA's pending rulemaking on NSPS for greenhouse gases at existing fossil-fuel fired power plants. Continue to discuss the electricity/natural gas nexus with Congress, FERC, & EPA.Monitored Water Resources Development Act (WRDA) progress, with emphasis on Corps reform and dam safety.
Monitored smart grid programs and their intersection with the telecommunications industry, and responded to requests for meetings and information on the subject to DOE. Supported the need to allow electric utilities to access spectrum for wireless; monitored implementation of S. 911 at NTIA. Monitored the issue of "retransmission consent" with regard to access to cable programming.
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2012 · fourth_quarter · Q4
Monitored smart grid programs and their intersection with the telecommunications industry, and respond to requests for meetings and information on the subject to DOE. Supported the need to allow electric utilities to access spectrum for wireless; monitored implementation of S. 911 at NTIA. Monitored the issue of "retransmission consent" with regard to access to cable programming.
Support the continued use of tax-exempt financing for municipal/public power purposes, and oppose provisions, like those included in the Administration's FY 2013 budget proposal and S. 727, to tax municipal bonds. Closely monitored development of H.R. 8 (compromise on fiscal cliff), and opposed any efforts to include taxation of municipal bonds in the legislation.
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2012 · third_quarter · Q3
Expressing concerns about or opposition to markets issues related to regional transmission organizations, including western energy imbalance market; opposed cyber security legislation involving the electric utility sector in the Senate -- revised version of S. 3414; supported H.R. 4273 regarding emergency operation of power plants and Clean Air Act violations. Monitored issues related to electric vehicles, particularly regarding funding issues. Monitor Senator Klobuchar bill related to preventing copper theft. Monitor rulemakings related to transmission policy, including transmission incentive rates. Work to ensure small utilities that are defined as small businesses under SBREFA, get appropriate consideration under any pending and future EPA and FERC regulations. Interface with DOE and DHS on recovery and resilience in the event of major disaster, as recommended by the National Infrastructure Advisory Committee (NIAC).
Support legislation to define parameters of EPA regulation of coal ash as a non-hazardous waste -- H.R. 1391, H.R. 2273 & S. 1751. Express concerns about regulation of cooling water intake structures (known as 316(b)) by EPA. Concern about air regulations on power plants being promulgated by EPA, including utility MACT (MATS), and support for the TRAIN Act to require multiple agencies to do cost-benefit analysis of EPA regs -- H.R. 2401. Monitoring possible revisions to EPA's final rule on reciprocating internal combustion engines (RICE) -- EPA-HQ-OAR-2008-0708. Monitoring EPA's proposed rule on New Source Performance Standard (NSPS) on greenhouse gas emissions on power plants. Continue to express concerns, particularly to FERC and EPA, about fuel switching from coal to natural gas and the operational implications therein.
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2012 · second_quarter · Q2
Opposition to utility pole attachment regulations promulgated by the Federal Communications Commission. Monitor smart grid programs and their intersection with the telecommunications industry, and respond to requests for meetings and information on the subject to DOE. Support for the need to allow electric utilities to access spectrum for wireless; monitoring implementation of S. 911 at NTIA.
Support the continued use of tax-exempt financing for municipal/public power purposes, and oppose provisions, like those included in the Administration's FY 2013 budget proposal and S. 727, to tax municipal bonds. Oppose H.R. 4348, to rescind Clean Renewable Energy Bond allocations (the comparable incentive to the production tax credit for public power development of renewable resources).
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2012 · first_quarter · Q1
Supporting technology research and development related to electricity infrastructure technologies, including smart grid; expressing concerns about electricity markets issues related to regional transmission organizations; monitoring cyber security legislation involving the electric utility sector, including S. 1342, as well as the House GRID Act from the previous Congress (now in draft form), the SHIELD Act from this Congress, and the draft Seante HSGAC/Commerce bill from this Congress. and the House Intelligence Committee cyber bill from this Congress (Rogers bill). Monitor rulemakings, legislation, & hearings related to transmission policy, including transmission incentive rates. Monitor funding and other policy issues related to electric vehicles and their integration into the electric grid. Discussion with FEMA regarding mutual aid agreements and utility restoration after natural disasters. Support draft legislation to enable power plants to run in emergency situations without being penalized by EPA for environmental (emissions) violations (Olson-Terry bill). Monitor efforts by DOE to expedite transmission siting on federal lands per authority under the Energy Policy Act of 2005. Ensuring utilities were treated appropriately for purposes of allowing eminent domain under private property rights bill -- H.R. 1433. Work to ensure small utilities that are defined as small businesses under SBREFA, get appropriate consideration under any pending and future EPA and FERC regulations.
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2011 · fourth_quarter · Q4
Support legislation to define parameters of EPA regulation of coal ash as a non-hazardous waste -- H.R. 1391 and H.R. 2273. Expressing concerns about regulation of cooling water intake structures (known as 316(b)) by EPA as well as anticipated revised effluent guidelines by EPA. Concern about air regulations on power plants being promulgated by EPA, including utility MACT, and support for the TRAIN Act to require multiple agencies to do cost-benefit analysis of EPA regs -- H.R. 2401. Monitoring effluent guidelines revisions in terms of the impact of chemical treatments used at power plants on wetlands. Monitoring possible revisions to EPA's final rule on reciprocating internal combustion engines (RICE).
Opposition to utility pole attachment regulations promulgated by the Federal Communications Commission. Monitoring smart grid programs and their intersection with the telecommunications industry, and responding to requests for meetings and information on the subject to DOE. Monitoring privacy-related bill involving data collection through smart grid, S. 1029 -- have concerns about bill as drafted. Support for the need to allow electric utilities to access spectrum for wireless; monitoring S. 911.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2011 · third_quarter · Q3
Support legislation to define parameters of EPA regulation of coal ash as a non-hazardous waste -- H.R. 1391 and H.R. 2273. Expressing concerns about regulation of cooling water intake structures (known as 316(b)) by EPA as well as anticipated revised effluent guidelines by EPA. Concern about air regulations on power plants being promulgated by EPA, including utility MACT, and support for the TRAIN Act to require multiple agencies to do cost-benefit analysis of EPA regs -- H.R. 2401. Monitoring effluent guidelines revisions in terms of the impact of chemical treatments used at power plants on wetlands. Monitoring possible revisions to EPA's final rule on reciprocating internal combustion engines (RICE).
Supporting technology research and development related to electricity infrastructure technologies, including smart grid; expressing concerns about electricity markets issues related to regional transmission organizations; monitoring cyber security legislation involving the electric utility sector, including S. 1342, as well as the House GRID Act from the previous Congress (now in draft form), the SHIELD Act from this Congress, and the House Intelligence Committee cyber bill from this Congress. Monitoring rulemakings, legislation, & hearings related to transmission policy, including transmission incentive rates. Monitor funding and other policy issues related to electric vehicles and their integration into the electric grid. Discussion with FEMA regarding mutual aid agreements and utility restoration after natural disasters.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2011 · third_quarter · Q3
Supporting technology research and development related to electricity infrastructure technologies, including smart grid; expressing concerns about electricity markets issues related to regional transmission organizations; monitoring cyber security legislation involving the electric utility sector, including S. 1342, as well as the House GRID Act from the previous Congress (now in draft form) and the SHIELD Act from this Congress. Monitoring rulemakings, legislation, & hearings related to transmission policy.
Support legislation to define parameters of EPA regulation of coal ash as a non-hazardous waste -- H.R. 1391 and H.R. 2273. Expressing concerns about regulation of cooling water intake structures (known as 316(b)) by EPA as well as anticipated revised effluent guidelines by EPA. Concern about air regulations on power plants being promulgated by EPA, including utility MACT, and support for the TRAIN Act to require multiple agencies to do cost-benefit analysis of EPA regs -- H.R. 2401.
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2011 · second_quarter · Q2
Support for the Rockefeller two-year delay bill (to delay EPA from regulating stationary sources of GHG emissions for two years) and the Energy Tax Prevention Act. Concern about the possibility of EPA regulating coal ash as a hazardous waste instead of allowing for beneficial uses -- support for Shimkus bill. Concerns about upcoming regulation of cooling water intake structures (known as 316(b)) by EPA. Concern about air regulations on power plants being promulgated by EPA, including utility MACT.
Support for certain energy policy provisions included in S. 1462 from the last Congress, including plug-in hybrid electric vehicle programs, creation of the Clean Energy Development Administration, and energy efficiency programs. Monitoring the Hydropower Improvement Act. Monitoring and commenting on the idea of a Clean Energy Standard as proposed by President Obama.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2011 · first_quarter · Q1
Support for certain energy policy provisions included in S. 1462 from the last Congress, including plug-in hybrid electric vehicle programs, creation of the Clean Energy Development Administration, and energy efficiency programs. Monitoring the Hydropower Improvement Act. Monitoring and commenting on the idea of a Clean Energy Standard as proposed by President Obama.
Support for the Rockefeller two-year delay bill (to delay EPA from regulating stationary sources of GHG emissions for two years) and the Energy Tax Prevention Act. Concern about the possibility of EPA regulating coal ash as a hazardous waste instead of allowing for beneficial uses. Concerns about upcoming regulation of cooling water intake structures (known as 316(b)) by EPA. Concern about air regulations on power plants being promulgated by EPA, including utility MACT.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2011 · first_quarter · Q1
Supporting technology research and development related to electricity infrastructure technologies, including smart grid; expressing concerns about electricity markets issues related to regional transmission organizations, and seeking legislation to enhance data transparency in those markets; monitoring cyber security legislation involving the electric utility sector, including the cyber title of S. 1462 from the previous Congress as well as the GRID Act from the previous Congress and the SHIELD Act from this Congress.
Support for the Rockefeller two-year delay bill (to delay EPA from regulating stationary sources of GHG emissions for two years) and the Energy Tax Prevention Act. Concern about the possibility of EPA regulating coal ash as a hazardous waste instead of allowing for beneficial uses. Concerns about upcoming regulation of cooling water intake structures (known as 316(b)) by EPA. Concern about air regulations on power plants being promulgated by EPA, including utility MACT.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2010 · fourth_quarter · Q4
Support technology research and development related to electricity infrastructure technologies, including smart grid, some positive provisions have been included in S. 1462; expressing concerns about electricity markets issues related to regional transmission organizations, and seeking legislation to enhance data transparency in those markets; monitoring cyber security legislation involving the electric utility sector, including the cyber title of S. 1462, as well as S. 3480 and S. 3538.
Monitoring regional transport rule at EPA, and its relationship to the Carper 3-pollutant bill, S. 2995. Support for the Rockefeller two-year delay bill (to delay EPA from regulating stationary sources of GHG emissions for two years). Concern about the possibility of EPA regulating coal ash as a hazardous waste instead of allowing for beneficial uses. Concerns about upcoming regulation of cooling water intake structures (known as 316(b)) by EPA.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2010 · third_quarter · Q3
Support for certain energy policy provisions included in S. 1462 and H.R. 2454 that could be considered as stand-alone legislation, including plug-in hybrid electric vehicle programs, creation of the Clean Energy Development Administration, energy efficiency programs, a workable 15% renewable portfolio standard, and transmission siting provisions. Monitoring Home Star and Rural Star legislation.
Monitoring regional transport rule at EPA, and its relationship to the Carper 3-pollutant bill, S. 2995. Support for the Rockefeller two-year delay bill (to delay EPA from regulating stationary sources of GHG emissions for two years). Concern about the possibility of EPA regulating coal ash as a hazardous waste instead of allowing for beneficial uses. Concerns about upcoming regulation of cooling water intake structures (known as 316(b)) by EPA.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2006 · year_end · YY
-Implementation of the Energy Policy Act of 2005 -Any issues related to the Federal Energy Regulatory Commission, Regional Transmission Organizations and electricity markets -Federal Power Marketing Administration issues -nuclear energy -climate change
-Railroad issues -- specifically pertaining to coal shippers
-municipal broadband deployment -anti-trust issues related to the telecommunications marketplace
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2006 · mid_year · MM
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), SENATE, Treasury, Dept of
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2005 · year_end · YY
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), SENATE, Surface Transportation Board (STB), Treasury, Dept of
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2005 · mid_year · MA
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, SENATE, Surface Transportation Board (STB), Treasury, Dept of
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2004 · year_end · YY
Filing targets: Commerce, Dept of (DOC), Council on Environmental Quality (CEQ), Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), Office of Management & Budget (OMB), SENATE, Surface Transportation Board (STB), Transportation, Dept of (DOT)
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2004 · mid_year · MM
Filing targets: Commerce, Dept of (DOC), Council on Environmental Quality (CEQ), Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), Office of Management & Budget (OMB), SENATE, Surface Transportation Board (STB), Transportation, Dept of (DOT), White House Office
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2003 · mid_year · MM
Filing targets: Commerce, Dept of (DOC), Council on Environmental Quality (CEQ), Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), Office of Management & Budget (OMB), SENATE, Surface Transportation Board (STB), Transportation, Dept of (DOT), Treasury, Dept of, White House Office
Discussed concerns with third-party efforts to remove the Lower Snake River Dams and the importance of hydropower (no bill). Discussed President Trumps Executive Order, Empowering Commonsense Wildfire Prevention and Response, and APPAs support for efforts to improve interagency coordination on wildfires. Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusions for vegetation management along power line rights-of-way on federal lands. Discussed support for H.R. 2492, the Fire Safe Electrical Corridors Act of 2025 (all provisions). Discussed concerns with section 60062 in H.R. 1, the One Big Beautiful Bill Act, provision to allow for faster review of environmental assessments and environmental impact statements under the National Environmental Policy Act. Discussed H.R. 3637, the Locally Led Restoration Act of 2025, to allow public and private entities to enter into stewardship contracts with the Forest Service and the Bureau of Land Management if the goals of a project include the removal of vegetation and at least 10 percent of the vegetation proposed to be removed is salvage, meaning wildfire kill, beetle kill, and dead or dying organic material.
Discussed the regulatory uncertainty created by the legacy Coal Combustion Residuals rulemakings that are currently under review (Docket No. EPA-HQ-OLEM-202-0107).
Discussed the provisions the Senate version of H.R. 1, the One Big Beautiful Bill Act, to auction licenses in the 6 gigahertz (GHz) band and the potential impact it could have on public power utilities that rely on the 6 GHz band for critical utility communications. Discussed how House version of H.R. 1 did not include similar language.
Discussed general support for the repeal of the 2024 Carbon Pollution Standard (Docket No. EPA-HQ-OAR-2025-0124). Discussed the potential reliability impacts from the rule, as well impracticality of using carbon capture and storage technology to reduce emissions given the current state of the technology. Discussed concerns with the 2024 Effluent Limitation Guidelines Rule and the costs of various waterwater treatment technologies required to comply with the rule (Docket No. EPA-HQ-OW-2009-0819). Discussed the administrations plans to reconsider the rule and the challenges with meeting the compliance deadlines in the 2024 rule. Discussed and provided feedback on draft legislation to amend the Clean Water Act to improve the federal permitting process. Discussed support for H.R. 3898, the PERMIT Act, to improve the permitting process for infrastructure projects under the Clean Water Act, provision regarding nationwide permitting and the determination of the appropriate acreage threshold for discharges into WOTUS, and provision regarding section 18 statutory exclusion from the regulatory definition of WOTUS for waste treatment systems. Also discussed section 6, clarifying federal general permits, and section 15, judicial review timelines clarity. Discussed proposal by the Army Corps of Engineers to reissue or modify the 2021 Nationwide Permits (NWPs) under section 404 of the Clean Water Act and section 10 of the Rivers and Harbor Act of 1899. Discussed the need to quickly issue and finalize an NWP rulemaking to assist energy infrastructure projects (DOE/COE; RIN 0710-AB56).
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
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 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
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 concerns with the DOEs proposed energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they would worsen the distribution transformer supply chain crisis. 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 support for S. 3627, the Distribution Transformer Efficiency and Supply Chain Reliability Act of 2024 (all provisions). Discussed the need for the FAQS for the Fiscal Years 2022-2023 Funding Cycle for the Department of Energy's Grid Resilience and Innovation Partnerships (GRIP) Program (P.L. 117-58, sections 40101, 40103, and 40107) to be clarified regarding eligibility for joint action agencies. Discussed support for DOE's GRIP Program (P.L. 117-58, sections 40101, 40103, and 40107). Discussed ways to improve DOE outreach to smaller and rural utilities. Discussed the importance of improving the hydropower licensing and relicensing process (no bill). 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, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed H.R. 6185, the Guaranteeing Reliable Infrastructure Development (GRID) 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 making transmission investment tax credits refundable in CETA, direct pay tax credits. 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 concerns with 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 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 across the U.S. Discussed the development of Western markets. Discussed President Bidens Executive Order to promote the safe, secure, and trustworthy development and use of artificial intelligence (AI). Discussed the potential use of AI by electric utilities. Discussed the National Cyber Incident Response Plan. Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort. Also discussed concerns with how the federal permitting process is slowing the ability of NTUA and volunteers to connect additional Navajo Nation homes to the electric grid.
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 section 242 of H.R. 2811, the Limit, Save, Grow Act of 2023, that would repeal the taxpayer election of payments, in lieu of credits, for specified energy property and production of electricity from certain renewable resources. Discussion of 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 Treasury guidance relating to utility assistance use of funding under section 5001 of the CARES Act (Coronavirus State and Local Fiscal Relief Funds) as amended by the Consolidated Appropriations Act of 2020. Discussed support for H.R. 1837, the Investing in Our Communities Act to reinstate the ability to issue tax-exempt advance refunding bonds (all provisions). Discussed support for S. 1453, the Lifting Our Communities through Advance Liquidity for Infrastructure Act (LOCAL Infrastructure Act), to reinstate the ability to issue tax-exempt advance refunding bonds (all provisions). Discussed support for potential legislation to increase the small-issuer exception from $10 million to $30 million. Discussed concerns with Proposed Rule: Section 45V Credit for Production of Clean Hydrogen; Section 48(a)(15) Election to Treat Clean Hydrogen Production Facilities as Energy Property (88 FR 8920, REG-117631-23 (additionality requirements for clean power used to generate hydrogen).
Filing targets: Energy, Dept of, Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), SENATE, Treasury, Dept of, White House Office
Discussed the exemption in section 224 of the Communications Act that precludes Federal Communications Commission regulation of public power pole attachments. Expressed opposition to any attempt to repeal or weaken the exemption. Discussed concerns with electric customers being forced to subsidize for-profit communications companies. Provided feedback on draft legislation, the FAIR Poles Act (all provisions), to link receipt of broadband funding under the Infrastructure Investment and Jobs Act (P.L. 117-58) to fixed federal pole attachment rates. Discussed support for H.R. 2552, the Community Broadband Act of 2023, to enable public power utilities to provide or assist in providing broadband services.
Filing targets: Agriculture, Dept of (USDA), Energy, Dept of, Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
Discussed the importance of direct pay refundable energy tax credits for public power investments in clean energy technologies to address climate change. Discussed the implementation of the refundable direct pay tax credit provisions included in the Inflation Reduction Act (P.L. 117-1), including the requirement to meet domestic content rules and the timing of refundable direct pay tax credit elections and returns. Discussed the need to restore advance refunding bonds and support for legislation in 117th Congress, the Investing in Our Communities Act (all provisions). Discussed support for H.R. 1837, the Investing in Our Communities Act (all provisions), to restore advance refunding bonds. Discussed potential legislation to waive PAYGO sequestration of direct payment bonds and refundable tax credits.
Discussed grid security issues, including implementation of mandatory cyber incident reporting legislation (included in the Consolidated Appropriations Act, 2022 (P.L. 117-103)) by the Department of Homeland Securitys Cybersecurity and Infrastructure Security Administration (DHS CISA) and the need to avoid duplicative or conflicting reporting requirements. Discussed the need for DHS CISA to undertake a careful and deliberative implementation process that takes into account existing reporting mandates and to appropriately tailor reporting mandates commensurate with risk to national security. 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 how the federal government should play a greater role in helping electric utilities in assessing vendor cybersecurity practices, such as establishing a federal vendor certification or accreditation program. Discussed concerns with H.R. 1160, the Critical Electric Infrastructure Cybersecurity Incident Reporting Act (all provisions). Discussed draft legislation to direct state public utility commissions to establish cybersecurity baselines for distribution utilities (no bill number). Discussed public powers cybersecurity needs, capabilities, and priorities as the Department of Energy (DOE) works to implement the Rural and Municipal Utility Advanced Cybersecurity Grant Program. 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 DOE to address the distribution transformer supply chain crisis, including President Bidens declaration to use the Defense Production Act. Discussed concerns with the DOEs proposed energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they would worsen the distribution transformer supply chain crisis. Discussed the creation of a transformer manufacturing loan program (no legislation). Discussed need for increased domestic manufacturing of equipment for electric utilities. Discussed FERC-DOE technical conference on supply chain risk management (Docket AD22-12). Discussed the importance of hydropower as a source of renewable energy for public power utilities. Discussed the importance of hydropower for grid reliability. Provided feedback on unintroduced, updated version of legislation from the 117th Congress, the BIG WIRES Act, to give the Federal Energy Regulatory Commission (FERC) the authority to require the expansion of transmission facilities for reliability, among other things (all provisions). Provided feedback on FERC-related bills from the 117th Congress (all provisions): the Interregional Transmission Planning Improvement Act; the Right to Timely Rehearings at FERC Act; the Empowering RTO Stakeholders Act; the Reinforcing the Grid Against Extreme Weather Act; and the Responsive Energy Demand Unlocks Clean Energy (REDUCE) Act. Discussed support for permitting reform to help expedite the construction of energy infrastructure (no bill), including changes to the National Environmental Policy Act (NEPA) and changes to the Federal Power Act to expedite the construction of transmission while not saddling public power utilities with transmission costs for which they receive no benefit. Discussed the provisions in H.R. 1, the Lower Energy Costs Act, to reform NEPA and to make it easier to deal with hazard trees near electric infrastructure on federal lands. Discussed the development of an energy market in the West. Discussed the importance of the Low Income Home Energy Assistance Program and potential ways to strengthen the program. Discussed implementation of the Infrastructure Investment and Jobs Act (P.L. 117-58) and how funding for electric vehicle charging infrastructure, grid resilience, cybersecurity, and clean energy technologies will benefit public power utilities. Discussed concerns with the DOEs draft guidance to implement section 247 (Maintaining and Enhancing Hydroelectric Incentives) in the Infrastructure Investment and Jobs Act (P.L. 117-58). Discussed the public power business model. Discussed generation resource adequacy and the pace of electric industry change. Discussed transmission planning issues (FERC RM21-17). Discussed reliability and physical security issues (FERC Docket Nos. RD22-3; RD22-4; and RM22-12). Discussed California natural gas price spike concerns.
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Intl Trade Administration (ITA), Labor, Dept of (DOL), Natl Security Council (NSC), Office of Management & Budget (OMB), SENATE, Transportation, Dept of (DOT), Treasury, Dept of
Discussed public powers support for legislation to address climate change, including potential legislation to create a clean energy standard and what such legislation would need to include to ensure electricity remains affordable, reliable, and sustainable. Discussed what public power utilities are doing to reduce their greenhouse gas emissions. Discussed the impact the Environmental Protection Agencys Effluent Limitations Guidelines rulemaking could have on public power utilities (2020 Steam Electric Reconsideration Rule, EPA-HQ-OW-2009-0819). Discussed greenhouse gas emissions control technology for combustion turbines (EPA-HQ-OAR-2022-0289). Discussed non-regulatory docket responding to pre-proposal questions on new greenhouse gas requirements for electric generating units under Clean Air Act section 111(d) and 111(b) rules (EPA-HQ-OAR-2022-0723). Discussed the proposed Federal Implementation Plan on the 2015 Ozone and potential impact on public power utilities (NAAQS-EPA-HQ-OAR-2021-0668). Discussed the non-regulatory docket on requirements to control greenhouse gas emissions from new and existing electric generating units (EPA-HQ-OAR-2022-0723).
Discussed the importance of direct pay refundable energy tax credits for public power investments in clean energy technologies to address climate change. Discussed the implementation of the refundable direct pay tax credit provisions included in the Inflation Reduction Act (P.L. 117-1). Discussed potential legislation to wave PAYGO sequestration of direct payment bonds and refundable tax credits. Discussed provision to delay PAYGO sequestration in H.R. 2617, Consolidated Appropriations Act, 2023. Discussed support for S. 2306, Maintaining and Enhancing Hydroelectric and River Restoration Act of 2021 (all provisions).
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), SENATE, Treasury, Dept of
Discussed the importance of direct pay refundable energy tax credits for public power investments in clean energy technologies to address climate change. Discussed support for the provisions in H.R. 5376, the Build Back Better Act, to make refundable, direct pay energy tax credits available to public power utilities - subtitle F, parts 1 (Renewable Electricity and Reducing Carbon Emissions) and 8 (Incentives for Clean Electricity and Transportation). Discussed S. 986, the Carbon Capture, Utilization, and Storage Tax Credit Amendments Act of 2021 (direct pay provision). Discussed the need to restore advance refunding bonds and support for H.R. 2288, the Investing in Our Communities Act, and S. 479, the LOCAL Infrastructure Act. Discussed the need to increase the small-issuer exception. Discussed support for H.R. 2634, the Local Infrastructure Financing Tools Act (provision to increase the small-issuer exception). Discussed S. 1308, the American Bond Infrastructure Act, that would reinstate the ability to issue taxable direct payment bonds similar to Build America Bonds.
Discussed grid security issues, including implementation of the mandatory cyber incident reporting legislation (included in the Consolidated Appropriations Act, 2022 (H.R. 2471)) by the Department of Homeland Securitys Cybersecurity and Infrastructure Security Agency (DHS CISA) and the need to avoid duplicative or conflicting reporting requirements. Discussed the need for DHS CISA to undertake a careful and deliberative implementation process that takes into account existing reporting mandates and to appropriately tailor reporting mandates commensurate with risk to national security. Discussed draft legislation to establish cybersecurity baselines for distribution utilities. Discussed APPAs cooperative agreement with the Department of Energy (DE-OE-0000811), Improving the Cyber Resiliency and Security Posture of Public Power, and how APPA used the funding to work with its members to improve their cyber hygiene. Discussed APPA's cooperative agreement with the Department of Energy (DE-CR0000007) and how APPA will use funding to help its members develop and deploy active cyber defense on public power operational technology networks. Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed the impact the distribution transformer shortage could have on restoring power after hurricanes. Discussed support for Department of Energy temporarily waiving distribution transformer energy efficiency standards to help spread raw steel materials and increase production volumes. Discussed how the Department of Energy will carry out Defense Production Act-related activities to accelerate domestic production of key technologies, strengthen U.S. power grid reliability, and deploy clean energy. Discussed the strategic transformer reserve provision in section 20301 of H.R. 4521, the America COMPETES Act of 2022. Discussed support for the Infrastructure Investment and Jobs Act (P.L. 117-58) and how it will help public power utilities make clean energy investments. Provided feedback on draft legislation, Leveraging our Water and Energy Data to Reduce (LOWER) Energy Bills Act (no bill number), and draft legislation to establish a National Model Building Performance Standard (no bill number). Provided feedback on draft legislation, the BIDIRECTIONAL Act, to promote vehicle-to-grid technologies. Discussed draft legislation to prohibit the shutoff of electric service during extreme weather events. Discussed the need for the reliable delivery of natural gas for electricity generation. Discussed H.R. 5749, the Gas Consumer Emergency Market Protection Act, and H.R. 6084, the Energy Product Reliability Act. Discussed transmission issues, including inter-regional transmission planning, cost allocation, siting, and permitting. Also discussed rising transmission costs for public power utilities and the need for joint ownership of transmission by public power utilities. In addition, discussed issues with the interconnection queue in certain regional transmission markets. Provided feedback on draft legislation, the BIG WIRES Act, to give the Federal Energy Regulatory Commission the authority to require the expansion of transmission facilities for reliability, among other things. Discussed the need for permitting reform to enable the siting and construction of energy infrastructure. Provided feedback on the transmission provisions in the Energy Independence and Security Act of 2022 (no bill number). Discussed the Federal Energy Regulatory Commissions (FERC) proposed directive to the North American Electric Reliability Corporation (NERC) to address concerns pertaining to transmission system planning for extreme heat or cold weather events that impact the reliable operation of the Bulk-Power System (RM-22-10). Discussed the cost management proposal in FERCs Notice of Proposed Rulemaking on Transmission Planning (RM-21-17). Discussed FERC regulation of public power utilities.
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, SENATE
Discussed draft legislation to fund middle mile broadband projects on electric grid infrastructure. Discussed draft version of American Data Privacy and Protection Act.
Discussed the importance of direct pay refundable energy tax credits for public power investments in clean energy technologies to address climate change. Discussed support for the provisions in H.R. 5376, the Build Back Better Act, to make refundable, direct pay energy tax credits available to public power utilities - subtitle F, parts 1 (Renewable Electricity and Reducing Carbon Emissions) and 8 (Incentives for Clean Electricity and Transportation). Discussed S. 986, the Carbon Capture, Utilization, and Storage Tax Credit Amendments Act of 2021 (direct pay provision). Discussed S. 627, the Energy Storage Tax Incentive & Deployment Act (proposed revision to allow for direct payment). Discussed the potential waiver of the deficit effects of the American Rescue Plan Act (Pub. Law 117-2) for purposes of the Pay as You Go Act (Pub. Law 111-39) to avoid sequestration of Build America Bonds payments.
Advocated for the President to take actions to modernize the Columbia River Treaty (focus on hydropower). Discussed status of the Columbia River Treaty negotiations. Discussed support for S. 4232, a bill to address the recovery of certain costs with respect to certain Reclamation facilities in the Colorado River Basin. Discussed support for amendment to S. 4137, the Water Resources Development Act of 2022, to clarify that Congress did not intend for funding provided to the Army Corps of Engineers in the Infrastructure Investment and Jobs Act (PL 117-58) and from the Extending Government Funding and Delivering Emergency Assistance Act (P.L. 117-43) to be paid back by federal hydropower customers. Discussed support for amendment to H.R. 7776, the Water Resources Development Act of 2022, to clarify that Congress did not intend for funding provided to the Army Corps of Engineers in the Infrastructure Investment and Jobs Act (PL 117-58) and from the Extending Government Funding and Delivering Emergency Assistance Act (P.L. 117-43) to be paid back by federal hydropower customers. Discussed the importance of hydropower (federal and non-federal) and the need for licensing and relicensing reform. Discussed opposition to breaching the Lower Snake River Dams. Discussed S. 3719, the Southwestern Power Administration Fund Establishment Act (all provisions). Discussed federal hydropower issues, including the impact of drought on hydropower production from federal dams, markets, rates, and finances. Discussed the anticipated increased costs to federal hydropower customers resulting from supplemental provided to the Army Corps of Engineers in the Infrastructure Investment and Jobs Act (P.L. 117-58) and from P.L. 117-43, the Extending Government Funding and Delivering Emergency Assistance Act. Discussed potential legislation to make changes to the National Environmental Policy Act to facilitate electric transmission siting.
Filing targets: Army, Dept of (Corps of Engineers), Council on Environmental Quality (CEQ), Energy, Dept of, Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Natl Economic Council (NEC), SENATE, White House Office
Discussed the importance of nuclear power and the importance of the nuclear provisions included in the Energy Act of 2020.
Discussed concerns with the Federal Communication Commission's 6 GHz Report and Order (Docket/RM: 18-295, 17-183 -- Unlicensed Use of the 6 GHz Band; Expanding Flexible Use in Mid-Band Spectrum Between 3.7 and 24 GHz) and efforts to allow more unlicensed devices to operate in the spectrum band used for critical infrastructure communications. Discussed how electric utilities are using broadband technologies. Discussed the exemption in Section 224 of the Communications Act that precludes Federal Communications Commission (FCC) regulation of public power pole attachments. Expressed opposition to any attempt to repeal or weaken the exemption.
Discussed support the inclusion of provisions to provide direct pay refundable energy tax credits to public power utilities in S. 2118, the Clean Energy for America Act. Discussed support for the inclusion of provisions in H.R. 5376, the Build Back Better Act, to make refundable, direct pay energy tax credits available to public power utilities - subtitle F, parts 1 and 8. Discussed support for S. 2306, the Maintaining and Enhancing Hydroelectricity and River Restoration Act of 2021, discussed support for the inclusion of a 30 percent tax credit to support upgrades at existing hydroelectric dams for qualified dam safety, environmental, and grid resilience improvements in the Senate version of the Build Back Better Act; (no bill number). Discussed support for H.R. 2288, the Investing in Our Communities Act, to restore advance refunding bonds. Discussed support for legislation to increase the small-issuer exception - H.R. 2634, the Local Infrastructure Financing Tools Act. Discussed concerns with the sequestration of direct payment bonds, including Build America Bonds and New Clean Renewable Energy Bonds. Discussed potential legislation to waive the deficit effects of the American Rescue Plan Act (Pub. Law 117-2) for purposes of the Pay as You Go Act (Pub. Law 111-39) to avoid sequestration of Build America Bonds payments.
Discussed the implementation of provisions in H.R. 3684, the Infrastructure Investment and Jobs Act, to provide grants to public power utilities and other entities to deploy charging infrastructure along designated corridors on the National Highway System. Discussed what public power is doing to enable electric vehicles (EVs), including support for federal incentives included in H.R. 3684, the Infrastructure Investment and Jobs Act, and the ability of public power utilities to have access to those incentives. Discussed the role of public power utilities in helping deploy EV charging infrastructure. Also discussed public power EV rebate programs and EV fleet programs. In addition, discussed the need for flexibility and local decision making in the deployment of charging infrastructure and the importance of electric utility involvement in such deployment to ensure reliability. Discussed role of electric utilities in National Electric Vehicle Infrastructure (NEVI) program, including the need for engagement with utilities on state plans and siting decisions and the potential for federal funding to cover EV "make-ready" costs that would otherwise be borne by utility or site host. Discussed the use of drones by electric utilities for operations.
Discussed bills to require cyber incident reporting by critical infrastructure sectors to the federal government - S. 2875, the Cyber Incident Reporting Act of 2021 (all provisions); H.R. 5440, the Cyber Incident Reporting for Critical Infrastructure Act of 2021 (all provisions); S. 2407, the Cyber Incident Notification Act of 2021 (all provisions); S. 3600, the Strengthening American Cybersecurity Act (all provisions); and H.R. 2471, the Consolidated Appropriations Act of 2022 (cyber incident reporting provision in Division Y - this was eventually signed into law). Discussed implementation of cyber incident reporting legislation included in the Consolidated Appropriations Act, 2022 (H.R. 2471). Discussed the importance of protecting the role of the Department of Energy (DOE) as the energy sectors risk management agency. Discussed comments APPA filed with DOE to its Request for Information, entitled Energy Sector Supply Chain Review. Discussed industry-wide transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed the strategic transformer reserve provision in section 20301 of H.R. 4521, the America COMPETES Act of 2022. Discussed several DOE grants APPA has received to support the cybersecurity posture of public power utilities, as well as to deploy cyber and cyber-physical solutions for public power utilities. Discussed public power utilities' efforts to transition to cleaner energy technologies, efforts to advance electrification, and modernize the grid. Discussed challenges public power utilities face in these efforts; and how programs in the Infrastructure Investment and Jobs Act could be helpful to public power utilities in their efforts. Discussed DOE's Notice of Intent (NOI) on Building a Better Grid Initiative To Upgrade and Expand the Nation's Electric Transmission Grid To Support Resilience, Reliability, and Decarbonization, which seeks to implement provisions from the Infrastructure Investment and Jobs Act, including the transmission needs study, the Transmission Facilitation Program, transmission corridor authority, and resiliency programs. Discussed implementation of the provisions in the Infrastructure Investment and Jobs Act by DOE on grid modernization, cybersecurity, resilience, and electric vehicles (EVs) (in coordination with the Department of Transportation (DOT)). Discussed implementation by DOE of provisions in H.R. 3684, the Infrastructure Investment and Jobs Act, that would be helpful to public power utilities, including provisions on cybersecurity, grid modernization, resilience, and the deployment of EV charging infrastructure (in conjunction with the DOT) (sections 11401, 40101, 40107, 40121, 40123, and 40124) and public powers transition to cleaner energy resources. Discussed the implementation of provisions in H.R. 3684, the Infrastructure Investment and Jobs Act, to provide grants to public power utilities and other entities to deploy charging infrastructure along designated corridors on the National Highway System. Discussed what public power is doing to enable EVs, including support for federal incentives included in H.R. 3684, the Infrastructure Investment and Jobs Act, and the ability of public power utilities to have access to those incentives. Discussed the role of public power utilities in helping deploy EV charging infrastructure. Also discussed public power EV rebate programs and EV fleet programs. In addition, discussed the need for flexibility and local decision making in the deployment of charging infrastructure and the importance of electric utility involvement in such deployment to ensure reliability. Discussed role of electric utilities in National Electric Vehicle Infrastructure (NEVI) program, including the need for engagement with utilities on state plans and siting decisions and the potential for federal funding to cover EV "make-ready" costs that would otherwise be borne by utility or site host. Discussed support for the inclusion of language in the Infrastructure Investment and Jobs Act to increase the Bonneville Power Administrations borrowing authority. Discussed support for the RD&D provisions in the Infrastructure Investment and Jobs Act to promote hydrogen, carbon capture and storage, and energy storage technologies. Discussed support for clean energy and research and development provisions in the Energy Act of 2020 (Division Z of H.R. 133, the Consolidated Appropriations Act, 2021). Discussed the importance of hydropower as an electricity resource for public power utilities and support for modernizing the hydropower licensing and relicensing process, including support for H.R. 1588, the Hydropower Clean Energy Future Act. Discussed the need for the reliable delivery of natural gas for electricity generation. Provided feedback on H.R. 5749, the Gas Consumer Emergency Market Protection Act (all provisions). Discussed natural gas futures price spike and impact to some public power utilities. Provided feedback on potential a Federal Energy Regulatory Commission (FERC)-related bill, on regional transmission organizations, joint ownership of transmission, the need for regulatory reform on federal transmission siting, and the streamlining of hydropower relicensing process. Discussed transmission issues, including inter-regional transmission planning, cost allocation, siting, and permitting. Also discussed rising transmission costs for public power utilities and the need for joint ownership of transmission by public power utilities. In addition, discussed issues with the interconnection queue in certain regional transmission markets. Discussed support for siting and permitting reform to enable the construction of clean energy infrastructure, including transmission.
Discussed public powers concerns with the Clean Electricity Performance Program (CEPP) included in H.R. 5376, the Build Back Better Act, to require electric utilities to increase their percentage of clean electricity and the likely inability of many public power utilities to meet the annual compliance obligations. Discussed public powers support for legislation to address climate change, including potential legislation to create a clean energy standard and what such legislation would need to include to ensure electricity remains affordable, reliable, and sustainable. Discussed support for a new statutory framework for reducing greenhouse gas (GHG) emissions to address climate change. Discussed what public power utilities are doing to reduce their GHG emissions. Discussed policy considerations the Environmental Protection Agency (EPA) should take into account when developing its proposed rule to regulate GHG emissions from the power sector (RIN No. 2060-AV10; rules on Reciprocating Internal Combustion Engines; environmental justice activities, and Cross-State Air Pollution Rule Update (EPA-HQ-OAR-2020-0272)). Discussed how EPA should approach designing and harmonizing its rules to facilitate the clean energy transition to technologies that will benefit the countrys public health and environment (RIN No. 2060-AV10; rules on Reciprocating Internal Combustion Engines; environmental justice activities, and Cross-State Air Pollution Rule Update (EPA-HQ-OAR-2020-0272)). Discussed what federal agencies EPA should coordinate with as it develops regulations for the power sector (RIN No. 2060-AV10; rules on Reciprocating Internal Combustion Engines; environmental justice activities, and Cross-State Air Pollution Rule Update (EPA-HQ-OAR-2020-0272)). Discussed Environmental Protection Agency (EPA) docket EPA-HQ-OW-2021-0602 on the Revised Definition of Waters of the United States - Rule 1 and its potential impact on public power utilities. Discussed H.R. 4143, the Clean Energy Future Through Innovation Act - provisions to create a federal clean energy standard.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, SENATE, Transportation, Dept of (DOT)
Discussed provisions in H.R. 5376, the Build Back Better Act, regarding the book tax on corporate income; support for making refundable, direct pay energy tax credits available to public power utilities; and the inclusion of tax credits for hydropower. Discussed the need for comparable incentives for various energy-related tax credits for public power utilities (i.e., refundable, direct pay tax credits). Discussed support for S. 2306, the Maintaining and Enhancing Hydroelectricity and River Restoration Act of 2021, and its inclusion in the Senate draft of the Build Back Better Act (no bill number). Discussed provisions in H.R. 5376, the Build Back Better Act, on providing Rural Utilities Service loans and grants for renewable energy generation and retirement of debt related to fossil-fuel generation and providing refundable direct payment energy-related tax credits. Also discussed support to include language to reinstate advance refunding bonds and increase the small-issuer exception. Discussed concerns with the sequestration of direct payment bonds, including Build America Bonds. Expressed support for S. 610, the Protecting Medicare & American Farmers from Sequester Cuts Act (non-Medicare budget sequestration provisions to postpone for a year PAYGO sequestration cuts). Discussed Treasury guidance related to the taxation of household assistance provided by the Coronavirus State and Local Fiscal Recovery Funds (Pub. Law 117-2, the American Rescue Plan Act).
Discussed the potential impact of vaccine mandates on the Power Marketing Administrations and public power utilities (Executive Order #14043, Requiring Coronavirus Disease 2019 Vaccination for Federal Employees, and OSHA Emergency Temporary Standard 2021-007). Provided feedback on S. 2407, the Cyber Incident Notification Act of 2021. Provided feedback on S. 2875, the Cyber Incident Reporting Act of 2021, and H.R. 5440, the Cyber Incident Reporting for Critical Infrastructure Act of 2021 (all provisions). Discussed cybersecurity-related provisions in S. 1605, the Fiscal Year 2022 National Defense Authorization Act (i.e., on cyber incident reporting language and language on defense critical electric infrastructure). Discussed the importance of grid resilience and the role of the Electric Subsector Coordinating Council. Discussed implementation of provisions in H.R. 3684, the Infrastructure Investment and Jobs Act, that would be helpful to public power utilities, including provisions on cybersecurity, the deployment of EV charging infrastructure, and their transition to cleaner energy resources (sections 11401, 40101, 40107, 40121). Discussed barriers to public power utilities deploying renewables and policies that would be helpful for removing such barriers, such as providing public power utilities with various energy-related tax credits and money for research, development, and demonstration of emerging clean technologies. Discussed how public power utilities are enabling community solar projects. Discussed support for the inclusion of language in H.R. 3684, the Infrastructure Investment and Jobs Act, to move the Southwestern Power Administration to a self-financing model. Discussed the role of public power utilities in helping deploy electric vehicle (EV) charging infrastructure. Also discussed public power EV rebate programs and EV fleet programs. In addition, discussed the need for flexibility and local decision making in the deployment of charging infrastructure and the importance of electric utility involvement in such deployment to ensure reliability. Discussed the implementation of provisions in H.R. 3684, the Infrastructure Investment and Jobs Act, to provide grants to public power utilities and other entities to deploy charging infrastructure along designated corridors on the National Highway System. Discussed transmission issues, including inter-regional transmission planning, cost allocation, siting, and permitting. Also discussed rising transmission costs for public power utilities and the need for joint ownership of transmission by public power utilities. In addition, discussed issues with the interconnection queue in certain regional transmission markets. Discussed draft legislation to address natural gas prices, the Gas Consumer Emergency Protection Act. Discussed recommendations in the Federal Energy Regulatory Commission-North American Electric Reliability Corporation report entitled, The February 2021 Cold Weather Outages in Texas and the South Central United States.
Filing targets: Council on Environmental Quality (CEQ), Energy, Dept of, Environmental Protection Agency (EPA), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), Office of Management & Budget (OMB), SENATE, Transportation, Dept of (DOT), Treasury, Dept of, White House Office
Discussed the role of public power utilities in helping deploy electric vehicle (EV) charging infrastructure. Also discussed public power EV rebate programs and EV fleet programs. Discussed support for language in infrastructure legislation to provide grants to public power utilities and other entities to deploy charging infrastructure along designated corridors on the National Highway System. Expressed opposition to the potential inclusion of language in H.R. 3684, the INVEST Act, that would limit electric utilities role in the deployment of EV charging infrastructure.
Discussed cybersecurity-related amendments to S. 2377, the Energy Infrastructure Act, and potential impact to public power. Discussed support for H.R. 2931, the Enhancing Grid Security Through Public-Private Partnerships Act. Discussed S. 2483, the Improving Cybersecurity of Small Organizations Act. Discussed the NCS 100-Day Industrial Control Systems (ICS) Cybersecurity Initiative. Discussed concerns with the mandatory reporting mandates in S. 2407, the Cyber Incident Notification Act of 2021. Provided feedback on S. 2875, the Cyber Incident Reporting Act of 2021, and H.R. 5449, the Cyber Incident Reporting for Critical Infrastructure Act of 2021 (all provisions). Discussed the cybersecurity provisions in H.R. 3684, the Infrastructure Investments and Jobs Act, including support for information disclosure protection provisions and additional funding to the Department of Energy (DOE) for grants to public power utilities for cyber programs (Senate version). Provided feedback on provisions of interest to public power utilities in the Energy Infrastructure Act (discussion draft), which eventually became S. 2377 (electric vehicles (EVs), clean energy technologies, grid resilience, hydropower, and wildfire mitigation). Expressed opposition to the inclusion of the text of H.R. 4027, the Efficient Grid Interconnection Act, as an amendment to S. 2377, the Energy Infrastructure Act. Also opposed an amendment to the legislation that would make changes to the Federal Power Act to change the interstate transmission siting process. Discussed amendment by Senator Mark Kelly on the purchase of energy generated by Indian tribes or tribal energy development organizations by federal Power Marketing Administrations to S. 2377, the Energy Infrastructure Act. Discussed support for provisions in H.R. 3684, the Infrastructure Investment and Jobs Act, that would be helpful to public power utilities, including provisions on cybersecurity, the deployment of EV charging infrastructure, and their transition to cleaner energy resources (sections 11401, 40101, 40107, 40121). Discussed language in H.R. 3684, the Infrastructure Investment and Jobs Act, to allow the use of private activity bonds to finance carbon capture facilities. Discussed support for an amendment to H.R. 3684, the Infrastructure Investment and Jobs Act, to move the Southwestern Power Administration to a self-financing model. Discussed the H.R. 4326, the EV Map Act and support for the legislation. Discussed the role of public power utilities in helping deploy EV charging infrastructure. Also discussed public power EV rebate programs and EV fleet programs. Discussed support for language in infrastructure legislation to provide grants to public power utilities and other entities to deploy charging infrastructure along designated corridors on the National Highway System. Discussed opposition to amendments offered, but not made in order, to H.R. 3684, the INVEST Act, that would limit electric utilities role in the deployment of EV charging infrastructure (House version of legislation). Discussed transmission issues, including interregional transmission planning, cost allocation, siting, and permitting. Also discussed rising transmission costs for public power utilities and the need for joint ownership of transmission by public power utilities. Provided feedback on transmission provisions in H.R. 1512, the CLEAN Future Act. Discussed hydropower-related amendments to S. 2377, the Energy Infrastructure Act, to ensure that dam removal provisions do not apply to federal hydropower dams.
Discussed efforts in the House to develop a Clean Electricity Performance Program (CEPP) to require electric utilities to increase their percentage of clean electricity. Discussed concerns with the impact of the CEPP, as included in the House Energy & Commerce Committee portion of the Build Back Better Act (eventually H.R. 5376), would have on public power utilities. Discussed the potential for a clean energy standard with a national goal of 80 or 100 percent clean electricity by 2030 or 2035 to result in stranded assets for public power utilities. Discussed public powers support for legislation to address climate change, including potential legislation to create a clean energy standard and what such legislation would need to include to ensure electricity remains affordable, reliable, and sustainable. Discussed what public power utilities are doing to reduce their greenhouse gas (GHG) emissions. Discussed the need for the federal government to provide robust support for research, development, and demonstration of technologies needed to reduce GHG emissions. Discussed diversity, equity, and inclusion activities by public power utilities. Discussed potential environmental justice provisions that could be included in the Build Back Better Act (portion of bill developed by the House Energy & Commerce Committee). Discussed Environmental Protection Agency (EPA) docket EPA-HQ-OAR-2018-0794) on National Emission Standards for Hazardous Air Pollutants (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units - Reconsideration of Supplemental Cost Finding and Residual Risk and Technology Review. Discussed EPA Docket on Stream Electric Effluent Limitation Guidelines - Notice of Rulemaking Initiative: FLR 8794-04-OW. Discussed EPA Dockets (EPA-HQ-OLEM-2019-0173 and EPA-HQ-RCRA-2009-0640) on implementation of the Coal Combustion Residuals rule and closure in place/closure by removal options and techniques.
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), SENATE, Treasury, Dept of, White House Office
Discussed potential legislation to provide a investment tax credit for transmission facilities. Discussed potential legislation to incentivize the privatization of public assets. Discussed draft version of the Energy Sector Innovation Tax Credit - provisions related to the transfer of credits by certain public entities. Discussed the availability of energy-related production and investment tax credits to public power utilities under section 45 and 48 of the U.S. Code. Discussed the need for comparable incentives for various energy-related tax credits for public power utilities. Discussed S. 292, the Clean Energy for America Act - provisions relating to direct payment bonds and refundable direct payment tax credit for public power utilities. Also discussed the EV tax credit provisions and the definition of public power. Discussed support for an amendment to S. 2119, the Clean Energy for America Act, on tax credits for hydropower. Provided feedback and support for technical changes to S. 2306, the Maintaining and Enhancing River Restoration Act of 2021. Discussed direct pay provisions for tribes and the definition of governmental entities as taxpayers in the draft and introduced versions of H.R. 848, the Growing Renewable Energy and Efficiency Now (GREEN) Act. Also discussed provisions on tax credit normalization. Discussed legislation from the 116th Congress (H.R. 5409, the Incentivizing New and Valuable Energy Storage Technology Act) to provide a tax credit for energy storage and the need for it to be available to public power utilities. Discussed H.R. 3180, the Renewable Energy Investment Act - specifically refundable direct payment tax credits for public power utilities. Discussed the need to restore advance refunding bonds and support for H.R. 2288, the Investing in Our Communities Act, and S. 479, the LOCAL Infrastructure Act). Discussed the need to increase the small-issuer exception. Discussed H.R. 2634, the Local Infrastructure Financing Tools Act - provisions on increasing the small-issuer exception, to restore advance refunding bonds, and the use of direct payment bond proceeds for purchase power agreements. Provided feedback on H.R. 2482, the Microgrid Act. Discussed provisions to extend the tax credit to public power utilities, definition of qualifying equipment, and interconnection fees. Discussed support for legislation to increase the value of the 45Q tax credit for carbon capture utilization and storage technologies. Discussed the need to ease certain private-use restrictions on municipal bonds.
Discussed potential cybersecurity legislation to require incident reporting, systemically important infrastructure, and other proposals from the Cyberspace Solarium Commission. Provided feedback on draft legislation (no bill number). Discussed concerns with potential efforts to impose additional mandatory reporting requirements on electric utilities regarding grid security. Discussed support for H.R. 2931, the Enhancing Grid Security Through Public-Private Partnerships Act. Discussed draft legislation regarding ransomware. Discussed how the Department of Energy (DOE) is approaching energy sector supply chain security, including DOEs Request for Information (RFI) to replace the Executive Order on the Bulk Power System (EO 13920). Discussed the electric utility industry's efforts to protect the grid and its close work with the federal government on cyber and physical security through the Electricity Subsector Coordinating Council. Discussed existing, mandatory and enforceable reporting standards for electric utilities. Discussed the NCS 100-Day Industrial Control Systems (ICS) Cybersecurity Initiative. Discussed concerns with the draft Warner/Rubio cyber incident reporting legislation, including opposition to mandatory reporting mandates. Discussed concerns with provisions to direct the Federal Energy Regulatory Commission (FERC) to issue a rulemaking on rate incentives for advanced cybersecurity technology. Discussed support for H.R. 2928/S. 2199, the Cybersense Act of 2021. Discussed support for H.R. 3119, the Energy Emergency Leadership Act. Discussed threats from ransomware and potential solutions (no bill number). Discussed H.R. 1833, the Department of Homeland Security ICS Enhancement Act. Discussed the cybersecurity provisions in the Energy Infrastructure Act (no bill number), including support for information disclosure protection provisions and additional funding to DOE for grants to public power utilities for cyber programs. Discussed APPA response to DOEs RFI on Energy Sector Supply Chain Security. Discussed support for an amendment offered to S. 1260, the U.S. Competition and Innovation Act, to clarify that the Department of Homeland Security (DHS) must coordinate with DOE during cyber events affecting the electric sector. Also discussed potential amendments to the bill on electric sector related issues. Discussed support for amending S. 1316, the Cyber Response and Recovery Act, to ensure DHS coordinates with DOE during cyber events affecting the electric sector. Discussed support for DOE funding public power resiliency grants (no bill number). Discussed APPAs cooperative agreement with the Department of Energy (DE-OE-0000811), Improving the Cyber Resiliency and Security Posture of Public Power, and how APPA used the funding to work with its members to improve their cyber hygiene. Discussed APPA's cooperative agreement with the Department of Energy (DE-CR0000007) and how APPA will use funding to help its members develop and deploy active cyber defense on public power operational technology networks. Discussed derivatives of DOEs Cybersecurity Capability Maturity Model (C2M2). Discussed need for Congress to look into FEMAs denial of public assistance for control room sequestration during the COVID-19 pandemic. Discussed APPA Light Up Navajo Project to provide electric service to Navajo Nation families by using mutual aid from public power utilities to build the infrastructure needed to provide service. Discussed community solar issues and possible legislation to spur community solar. Also discussed concerns with creating a must-consider requirement section 111 of the Public Utility Regulatory Policies Act (PURPA) for community solar. Discussed details on the National Community Solar Partnership and provided examples of public power utilities with community solar projects. Discussed potential legislation promote demand response programs by electric utilities. Discussed work being done by public power utilities on green hydrogen. Also discussed work APPA did with Berkeley Lawrence National Laboratory on community solar. Discussed potential energy-related provisions that could be included in an infrastructure package, including ones on transmission and promoting clean energy technologies. Discussed the role of public power utilities in helping deploy electric vehicle (EV) charging infrastructure. Also discussed public power EV rebate programs and EV fleet programs. Discussed support for language in infrastructure legislation to provide grants to public power utilities and other entities to deploy charging infrastructure along designated corridors on the National Highway System. Provided feedback on EV provisions in H.R. 1512, the CLEAN Future Act. Expressed opposition to the potential inclusion of language in H.R. 3684, the INVEST Act, that would limit electric utilities role in the deployment of EV charging infrastructure. Discussed transmission issues, including interregional transmission planning, cost allocation, siting, and permitting. Also discussed the need for joint ownership of transmission by public power utilities. Provided feedback on H.R. 2678, the Interregional Transmission Planning Improvement Act. Noted concerns about costs, cost allocation, and firm transmission rights. Discussed concerns with H.R. 616, Emergency Water Is a Human Rights Act. Discussed calls by former FERC Commissioners to have FERC mandate all electric utilities participate in regional transmission organizations. Discussed initiative on transmission by the National Association of Regulatory Utility Commissioners. Discussed revisions to National Electric Reliability Corporation (NERC) reliability standard BAL-003. Also discussed low impact assets under NERC standard CIP-002. Discussed provisions in H.R. 1848, the LIFT America Act, on EVs, transmission, and distributed energy resources. Discussed potential hydropower-related provisions in draft infrastructure legislation.
Discussed the need for appropriations to the Environmental Protection Agency for federal and state permitting programs for coal combustion residuals. Discussed President Bidens fiscal year 2022 Budget Submission to Congress.
Discussed the role of public power utilities in helping deploy electric vehicle (EV) charging infrastructure. Also discussed public power EV rebate programs and EV fleet programs. Discussed support for language in infrastructure legislation to provide grants to public power utilities and other entities to deploy charging infrastructure along designated corridors on the National Highway System. Expressed opposition to the potential inclusion of language in H.R. 3684, the INVEST Act, that would limit electric utilities role in the deployment of EV charging infrastructure.
Discussed the exemption in Section 224 of the Communications Act that precludes Federal Communications Commission (FCC) regulation of public power pole attachments. Expressed opposition to any attempt to repeal or weaken the exemption. Discussed concerns with the potential inclusion of language in infrastructure legislation to weaken local control of public power utility pole attachments. Discussed public powers concerns with FCC proceeding to open the 6 GHz band to unlicensed users (FCC ET Docket No. 18-295 and GN Docket No. 17-183). Discussed support for H.R. 1631, the Community Broadband Act.
Filing targets: Agriculture, Dept of (USDA), Council on Environmental Quality (CEQ), Energy, Dept of, Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, SENATE, White House Office
Discussed efforts by public power utilities to help with electric vehicle (EV) deployment, including the deployment of charging infrastructure. Discussed support for the inclusion of the Clean Corridors Act (S. 674 in the 116th Congress) in infrastructure legislation. Discussed support for policies that allow public power utilities to help deploy electric vehicle charging infrastructure.
Discussed draft version of the Energy Sector Innovation Tax Credit - provisions related to the transfer of credits by certain public entities. Discussed the availability of energy-related production and investment tax credits to public power utilities under section 45 and 48 26 of the U.S. Code. Discussed draft version of the Clean Energy for America Act - provisions relating to direct payment bonds. Discussed draft legislation to provide a tax credit for energy storage and the need for it to be available to public power utilities. Discussed direct pay provisions for tribes and the definition of governmental entities as taxpayers in the draft and introduced versions of H.R. 848, the Growing Renewable Energy and Efficiency Now (GREEN) Act. Discussed the need for comparable incentives for various energy-related tax credits for public power utilities. Discussed the need to restore advance refunding bonds (referenced support for legislation from the 116th Congress, H.R. 2722, the Investing in Our Communities Act, and S. 479, the LOCAL Infrastructure Act). Discussed the need to increase the small-issuer exception. Provided feedback on draft legislation, the Microgrid Resilience Tax Credit Act. Discussed provisions to extend the tax credit to public power utilities. Discussed the provision in draft legislation, the Promoting Sustainable Energy Projects for Tribal Communities Act, related to tax return needed to be filed to claim credits. Discussed the need to make the energy storage tax credit available to public power utilities in the draft version of the Incentivizing New and Valuable Energy Storage Technology Act. Discussed support for the Driving America Forward Act (S. 1094 from the 116th Congress).
Discussed H.R. 7516, the Clean Energy Innovation and Deployment Act, all provisions, from the 116th Congress. Discussed H.R. 1512, the CLEAN Future Act, all provisions. Discussed climate policy, including APPAs support for federal legislation to address the issue. Discussed potential climate-related provisions that could be included in infrastructure legislation, including a clean energy standard and carbon tax. Discussed what public power utilities are doing to reduce their greenhouse gas emissions. Discussed impacts of the Effluent Limitations Guidelines and Standards for the Steam Electric Power Generating Point Source Category (EPA-HQ-OW-2009-0819) and Revised Definition of Waters of the U.S. (EPA-HQ-OW-2009-0149) on public power utilities.
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Natl Security Council (NSC), SENATE, White House Office
Discussed support for additional funding for the Low Income Home Energy Assistance Program in H.R. 133, the Consolidated Appropriations Act, 2021.
Discussed H.R. 7516, the Clean Energy Innovation and Deployment Act, all provisions. Discussed draft CLEAN Future Act. Discussed draft legislation, the Clean Air Act Amendments Act of 2020, to create a cap and trade program to address climate change. Discussed climate policy.
Filing targets: Energy, Dept of, Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), SENATE
Expressed support for making emergency supplemental funds appropriated to the Power Marketing Administrations, Army Corps of Engineers, and Bureau of Reclamation non-reimbursable in coronavirus relief legislation, including H.R. 925, the HEROS Act. Discussed support for additional funding for the Low Income Home Energy Assistance Program in H.R. 925, the HEROES Act. Discussed concerns regarding the August 24, 2020, Memorandum of Understanding between the Department of Energy, U.S. Bureau of Reclamation, and Army Corps of Engineers on Federal Hydropower. Discussed committee report language for H.R. 7613, the Energy and Water and Related Agencies Appropriations Act, 2021, to require an Energy Information Administration report on utility reporting of emissions related to retail customer usage. Discussed Pub. Law 116-94, the Energy and Water and Related Agencies Appropriations Act, 2020 - joint explanatory statement of managers on funding for cybersecurity grant programs.
Provided feedback on the H.R. 7516, the Clean Energy Innovation and Deployment Act, all provisions. Discussed draft CLEAN Future Act. Discussed climate policy. Discussed EPA docket EPA-HQ-OW-2009-0819 on Effluent Limitations Guidelines and Standards for the Steam Electric Power Generating Point Source Category.
Discussed S. 3688, Energy Infrastructure Protection Ac of 2020. Discussed S. 4795, the Cyber Sense Act. Expressed support for House consideration of H.R. 359, the Enhancing Grid Security through Public-Private Partnerships Act; H.R. 360, the Cyber Sense Act of 2020; and H.R. 362, the Energy Emergency Leadership Act. Discussed the electric utility industry's efforts to protect the grid and its close work with the federal government on cyber and physical security through the Electricity Subsector Coordinating Council. Discussed support for potential Crow amendment to the Fiscal Year 2021 National Defense Authorization Act (NDAA) on defense critical electric infrastructure (H.R. 6395). Discussed opposition to the Richmond amendment to the House NDAA bill that would require mandatory cyber incident reporting. Discussed support for Bacon amendment to the House NDAA bill to protect facilities with defense critical electric infrastructure. Discussed King amendment on cyber exercise to the Senate National Defense Authorization Act for Fiscal Year 2021 (S. 4049). Discussed efforts by the electric utility sector to ensure electric service during the COVID-19 pandemic, including efforts undertaken to protect utility workers, obtain testing for key utility personnel, and the need for personal protective equipment for key utility personnel. Also discussed contact tracing for utilities. Discussed APPAs cooperative agreement with the Department of Energy (DE-OE-0000811), Improving the Cyber Resiliency and Security Posture of Public Power, and how APPA is using funding to work with its members to improve their cyber hygiene. Discussed funding through the Department of Energys Office of Cybersecurity, Energy Security, and Emergency Response to develop and deploy cyber and cyber-physical solutions for distribution and municipal utilities. Discussed the impact of COVID-19 on public power utilities and how they were dealing with the pandemic from an operational standpoint; discussed what public power utilities are doing on customer shutoffs during the pandemic; discussed language to establish a federal moratoria on utility shutoffs and prevent the collection of debt included in H.R. 6800, the Health and Economic Recovery Omnibus Emergency Solutions (HEROES) Act. Discussed the creation of a forgivable loan program to assist public power utilities negatively impacted by COVID-19. Discussed priorities for inclusion in coronavirus relief legislation - forgivable loan program, restoration of advance refunding bonds, increasing the small-issuer exception, increased funding for Low Income Home Energy Assistance Program (LIHEAP), making emergency supplemental appropriations for the Power Marketing Administrations non-reimbursable; and providing public power utilities with comparable incentives for various energy-related tax credits. H.R. 6800, the Health and Economic Recovery Omnibus Emergency Solutions (HEROES) Act; H.R. 925, the HEROES Act; and the Health, Economic Assistance, Liability Protection, and Schools (HEALS) Act. Discussed the use of Coronavirus Relief Funds allocated under the CARES Act (Pub. Law 116-136) for utility customer assistance programs. Discussed support for increased funding for Coronavirus Relief Funds and more flexibility in the use of such funds. Discussed S. 4362, the Emergency Water and Energy Is a Human Right Act. Discussed the public power business model. Discussed draft legislation - the Expanding Access to Sustainable Energy Act. Discussed support for S. 2657, the American Energy Innovation Act. Discussed impact of Hurricane Laura on public power utility in Louisiana. Discussed H.R. 3079, the Energy Savings through Public-Private Partnerships Act of 2019. Discussed views on Federal Energy Regulatory Commission (FERC) on Cybersecurity Incentives. Discussed cybersecurity issues at public power communities that also provide water service. Discussed the following FERC dockets/matters - Transmission Incentives Notice of Proposed Rulemaking (PL 19-3-00) (RM20-10); Resource Adequacy and Capacity Markets (no docket); Performance Metrics (AD19-16); and Notice of Inquiry in RM 20-12 relating to coordinated cyber-attacks.
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Interior, Dept of (DOI), Office of Management & Budget (OMB), SENATE
Discussed APPA's opposition to President Trump's fiscal year 2021 budget proposal to divest the transmission assets of the Power Marketing Administrations (PMAs) and Tennessee Valley Authority and to require the PMAs to charge market-based rates. Expressed support for making emergency supplemental funds appropriated to the Power Marketing Administrations, Army Corps of Engineers, and Bureau of Reclamation non-reimbursable in coronavirus relief legislation, including H.R. 6800, the HEROS Act. Supported additional funding for the Low Income Home Energy Assistance Program in H.R. 6800, the HEROS Act. Lobbied for increased funding to the Environmental Protection Agency for federal and state permitting programs for coal combustion residuals in fiscal year 2021.
Discussed support for H.R. 3967, Municipal Bond Market Support Act (all provisions) and H.R. 2772, Investing in Our Communities Act (all provisions), and their inclusion in coronavirus relief legislation or infrastructure legislation - H.R. 2, the Moving Forward Act. Discussed the impact of public power utilities not receiving employer payroll tax credit for emergency paid sick leave and paid family leave in PL 116-227, the Families First Coronavirus Relief Act. Discussed draft refundable tax credit for arrearages incurred by utilities that suspended service disconnects during the COVID-19 national emergency. Discussed draft of Rewarding American Workers Act - provisions related to payroll tax credits for employers. Discussed H.R. 5523, Energy Sector Innovation Tax Credit - technical correction to ensure applicability to public power utilities. Discussed H.R. 7058, Rewarding American Workers Act - provisions related to payroll tax credits for employers. Discussed provisions relating to the transferability and direct payment of energy tax credits to public power utilities in the Clean Energy Innovation and Deployment Act of 2020 (draft legislation). Discussed draft of COVID private activity bond legislation - provisions relating to use of private activity bond for energy projects and acquisition of existing facilities. Discussed draft of Growing Renewable Energy and Efficiency Now (GREEN) Act - provision related to direct payment of energy tax credits to governmental owners. Also discussed once introduced as H.R. 7330. Discussed draft proposal to allow monetization of all business tax credits (applicability to public power). Discussed H.R. 2, Moving Forward Act - provisions relating to sequestration of infrastructure bonds. Discussed impact of PL 112-25, Budget Control Act of 2011 - provisions relating to sequestration of direct payment of Build America Bond credits.
Provided feedback on the Clean Energy Innovation and Deployment Act (draft climate change legislation), including provisions relating to the transferability and direct payment of energy tax credits to public power utilities.
Filing targets: Energy, Dept of, Federal Communications Commission (FCC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), SENATE
Discussed support for the restoration of advance refunding bonds and H.R. 2772, the Investing in Our Communities Act. Discussed the need for comparable incentives for public power investments in clean energy and energy storage, including support for S. 1288, the Clean Energy for America Act. Discussed H.R. 2704, the Renewable Energy Transferability Act. Discussed credit transferability in H.R. 5523, the Energy Sector Innovation Act. Discussed support for H.R. 3967, the Municipal Bond Market Support Act. Discussed the sequestration of direct payment bonds and impact on public power utilities. Discussed H.R. 5409, the Incentivizing New and Valuable Energy Storage Technology (INVEST Act), and the need to ensure public power utilities have a comparable energy storage incentive. Discussed H.R. 2096, the Energy Storage Tax Incentive and Deployment Act, and the need to ensure public power utilities have a comparable energy storage incentive. Discussed tax credit refundability in the Growing Renewable Energy and Efficiency Now (GREEN) Act (draft legislation); also discussed provision in GREEN Act related to the direct payment of enhanced deduction for energy efficiency improvements by governmental owners. Discussed Internal Revenue Service private use rules relating to commercial contracts. Discussed provisions in H.R. 6201, the Families First Coronavirus Response Act, that deny payroll tax credits for government employers and impact on public power utilities. Discussed the possible inclusion of energy-related tax credits in H.R. 748, the Coronavirus Aid, Relief, and Economic Security Act.
Discussed potential ways to address third-party liability concerns during a national security emergency and during a national public health emergency. Discussed APPAs cooperative agreement with the Department of Energy (DE-OE-0000811), Improving the Cyber Resiliency and Security Posture of Public Power, and how APPA is using funding to work with its members to improve their cyber hygiene. Discussed APPA's cooperative agreement with DOE's Infrastructure Security and Energy Restoration Division -Integrating State Energy Assurance and Federal Energy Emergency Response Initiatives with Local Energy Emergency Response (DE-OE0000757). Expressed support for H.R. 359 and S. 2095, the Enhancing Grid Through Public-Private Partnerships Act, to permanently authorize program assisting small- and medium-sized electric utilities with grid security. Discussed S. 3045, the Cybersecurity Vulnerability and Notification Act. Discussed S. 3418, the STORM Act. Discussed the electric utility industry's efforts to protect the grid and its close work with the federal government on cyber and physical security through the Electricity Subsector Coordinating Council. Discussed potential amendment to S. 2657, the American Energy Innovation Act, and the fiscal year 2021 National Defense Authorization Act to protect facilities with defense critical electric infrastructure. Discussed the need to bolster the Department of Energy's ability to protect critical electric infrastructure information. Discussed efforts by DOE to protect Defense Critical Electric Infrastructure. Provided feedback on S. 2556, the Protecting Resources on the Electric Grid with Cybersecurity Technology Act of 2019. Provided feedback on draft legislation, the Protecting Energy Infrastructure Act, to protect critical electric infrastructure information. Discussed the work the Office of Electricity at DOE is doing on defense critical electric infrastructure. Discussed S. 2094, the Enhancing State Energy Security Planning and Emergency Preparedness Act. Discussed support for language in S. 1706/H.R. 3079, the Energy Savings through Public-Private Partnerships Act, to carve out federal hydropower facilities from the definition of eligible federal facilities that can use energy savings performance contracts. Expressed opposition to efforts to remove such language from the legislation. Discussed efforts by the electric utility sector to ensure electric service during the COVID-19 pandemic, including efforts undertaken to protect utility workers, obtain testing for key utility personnel, and the need for personal protective equipment for key utility personnel. Discussed how public power utilities are addressing the COVID-19 pandemic, including the suspension of power shutoffs. Provided feedback on language in H.R. 6379, the Take Responsibility for Workers and Families Act, on power shutoffs and debt collection. Discussed the impact the COVID-19 pandemic is having on public power utilities and potential need for federal assistance in future COVID-19 legislation. Discussed public powers priorities in H.R. 748, the Coronavirus Aid, Relief, and Economic Security Act, including increased funding for the Low Income Home Energy Assistance Program and aid to state and local governments. Provided feedback on H.R. 5760, the Grid Security R&D Act. Expressed support for S. 2657, the American Energy Innovation Act. Discussed FERC docket RM 18-9 and the need for state and local regulators to be able to consent to aggregation of distributed energy resources on distribution systems in their jurisdictions. Also discussed the particular burdens the proposed rule would have on small utilities. Discussed the impact of wholesale mandatory capacity market Minimum Offer Price rules and performance requirements on public power utilities. FERC docket EL 16-49/EL 18-178 and ER 18-1314. Discussed FERC docket No. PL 19-3 on transmission incentives. Discussed concerns with mandatory capacity markets in the Eastern RTOs and the need to ensure public powers ability to self-supply power in those markets. Expressed support for S. 1602, the Better Energy Storage Act of 2019; provided feedback and expressed support for H.R. 2986, the House version of the BEST Act. Provided feedback on H.R. 1744, the Storage Technology for Operational Readiness and Generating Energy Act. Provided feedback on an amendment to H.R. 5428, the Grid Modernization Research and Development Act of 2019. Discussed grid modernization issues.
Discussed APPA's opposition to President Trump's fiscal year 2021 budget proposal to divest the transmission assets of the Power Marketing Administrations (PMAs) and Tennessee Valley Authority and to require the PMAs to charge market-based rates. Lobbied for increased funding to the Environmental Protection Agency for federal and state permitting programs for coal combustion residuals in fiscal year 2021. Expressed support for making emergency supplemental funds appropriated to the Power Marketing Administrations, Army Corps of Engineers, and Bureau of Reclamation non-reimburseable in H.R. 748, the Coronavirus Aid, Relief, and Economic Security Act. Supported additional funding for the Low Income Home Energy Assistance Program in H.R. 748, the Coronavirus Aid, Relief, and Economic Security Act.
Discussed reforms to the National Environmental Policy Act -- CEQ-2019-002. Discussed federal and state permitting programs for coal combustion residual impoundments.
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Office of Management & Budget (OMB), SENATE, White House Office
Discussed what public power utilities are doing to reduce their greenhouse gas emissions and support for policies that would reduce emissions, such as energy efficiency, the promotion of hydropower and nuclear power, and the promotion of electric vehicles. Discussed H.R 172, the New Source Review Permitting Improvement Act. Discussed S. 2662, the GAIN Act. Discussed the NESHAP: Coal- and Oil-Fired Electric Utility Steam Generating Units -- reconsideration of supplemental cost finding and residual risk and technology -- EPA-HQ-OAR-2018-0794 Discussed EPA's Affordable Clean Energy Rule (EPA-HQ-OAR-2017-0355: FRL-9995-70-OAR), Air Emissions Transport, Ozone National Ambient Air Quality Standards Implementation.
Discussed electric vehicles and the deployment of charging infrastructure by public power utilities. Also discussed electric vehicle infrastructure costs, including make-ready costs. Expressed support for S. 674, the Clean Corridors Act of 2019, and the inclusion of the legislation in S. 2302, Americas Transportation Infrastructure Act of 2019. Expressed support for H.R. 2664, the All-of-the-Above Federal Building Energy Conservation Act of 2019.
Discussed potential ways to address third-party liability concerns during a grid security emergency. Discussed APPAs cooperative agreement with the Department of Energy (DE-OE-0000811), Improving the Cyber Resiliency and Security Posture of Public Power, and how APPA is using funding to work with its members to improve their cyber hygiene. Expressed support for H.R. 359 and S. 2095, the Enhancing Grid Through Public-Private Partnerships Act, to permanently authorize program assisting small- and medium-sized electric utilities with grid security. Discussed the electric utility industry's efforts to protect the grid and its close work with the federal government on cyber and physical security through the Electricity Subsector Coordinating Council. Discussed draft bulk-power system/supply chain executive order. Discussed potential amendment to the fiscal year 2020 National Defense Authorization Act, S. 1790, to protect facilities with defense critical electric infrastructure. Discussed the need to bolster the Department of Energy's ability to protect critical electric infrastructure information. Provided feedback on S. 2556, the Protecting Resources on the Electric Grid with Cybersecurity Technology Act of 2019. Provided feedback on draft legislation, the Protecting Energy Infrastructure Act,to protect critical electric infrastructure information. Discussed the work the Office of Electricity at DOE is doing on defense critical electric infrastructure. Provided feedback on H.R. 1975, the Cybersecurity Advisory Committee Authorization Act of 2019. Discussed FERC docket RM 18-9 and the need for state and local regulators to be able to consent to aggregation of distributed energy resources on distribution systems in their jurisdictions. Also discussed the particular burdens the proposed rule would have on small utilities. Discussed the impact of wholesale mandatory capacity market Minimum Offer Price rules and performance requirements on public power utilities. FERC docket EL 16-49/EL 18-178. Discussed Public Utility Regulatory Policies Act of 1978 reform being considered by the Federal Energy Regulatory Commission. FERC NOI -- Docket No. RM 19-15 and No. AD 16-16. Discussed FERC dockets ER 18-169 and ER 19-1428 on ISO-NE capacity markets and fuel security. Discussed FERC docket RM 16-23 and AD 16-20-001 on energy storage in wholesale markets. Discussed FERC docket No. PL 19-3 on transmission incentives. Discussed concerns with mandatory capacity markets in the Eastern RTOs and the need to ensure public powers ability to self-supply power in those markets. Expressed support for S. 1602, the Better Energy Storage Act of 2019, and provided feedback on H.R. 2986, the House version of the BEST Act. Provided feedback on H.R. 5428, the Grid Modernization Research and Development Act of 2019. Provided feedback on H.R. 5527, the 21st Century Power Grid Act. Provided feedback on draft legislation, the Interregional Transmission Planning Improvement Act of 2019, which is now S. 3109/H.R. 5511.
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), Office of Management & Budget (OMB), SENATE
Discussed potential ways to address third-party liability concerns during a grid security emergency. Discussed APPAs cooperative agreement with the Department of Energy (DE-OE-0000811), Improving the Cyber Resiliency and Security Posture of Public Power, and how APPA is using funding to work with its members to improve their cyber hygiene. Expressed support for H.R. 359 and S. 2095, the Enhancing Grid Through Public-Private Partnerships Act, to permanently authorize program assisting small- and medium-sized electric utilities with grid security. Discussed the electric utility industry's efforts to protect the grid and its close work with the federal government on cyber and physical security through the Electricity Subsector Coordinating Council. Provided feedback on S. 2094, the Enhancing State Energy Security Planning and Preparedness Act. Provided feedback on S. 2333, the Energy Cybersecurity Act of 2019. Discussed the status of the Cyberspace Solarium Commission. Discussed electromagnetic pulse provisions in the fiscal year 2020 National Defense Authorization Act, S. 1790. Discussed potential amendment on defense critical electric infrastructure to S. 1790, the fiscal year 2020 National Defense Authorization Act. Provided feedback on S. 2556, the the Protecting Resources on the Electric Grid with Cybersecurity Technology Act of 2019. Provided feedback on draft legislation, the Protecting Energy Infrastructure Act,to protect critical electric infrastructure information. Discussed the work the Office of Electricity at DOE is doing defense critical electric infrastructure. Discussed the proposed Federal Energy Regulatory Commission and National Electric Reliability Corporation (NERC) staff white paper on NERC Critical Infrastructure Protection violation notices. Discussed FERC docket RM 18-9 and the need for state and local regulators to be able to consent to aggregation of DERs on distribution systems in their jurisdictions. Also discussed the particular burdens the proposed rule would have on small utilities. Discussed the impact of wholesale mandatory capacity market Minimum Offer Price rules and performance requirements on public power utilities. Discussed Public Utility Regulatory Policies Act of 1978 reform being considered by Federal Energy Regulatory Commission. Discussed support for the inclusion of language to improve the hydropower licensing and relicensing reform process in an energy title to an infrastructure bill or as stand-alone legislation. Provided feedback on draft energy storage legislation, which become S. 1602, the Better Energy Storage Act of 2019. Provided feedback H.R. 4447, the Expanding Access to Sustainable Energy Act of 2019. Discussed concerns with mandatory capacity markets in the Eastern RTOs and the need to ensure public powers ability to self-supply power in those markets. Provided feedback on draft legislation to promote grid modernization research and development.
Discussed the exemption in Section 224 of the Communications Act that precludes Federal Communications Commission (FCC) regulation of public power pole attachments. Expressed opposition to any attempt to repeal or weaken the exemption. Expressed support for H.R. 530, the Accelerating Broadband Development by Empowering Local Communities Act of 2019, to repeal the FCC's report and order that seeks to regulate public power pole attachments. Expressed opposition to S. 1699, the STREAMLINE Small Cell Deployment Act. Discussed public powers concerns with FCC proceeding to open the 6 GHz band to unlicensed users (FCC ET Docket No. 18-295 and GN Docket No. 17-183). Discussed S. 2223, the AIRWAVES Act. Discussed draft broadband legislation.
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), SENATE
Discussed the exemption in Section 224 of the Communications Act that precludes Federal Communications Commission (FCC) regulation of public power pole attachments. Expressed opposition to any attempt to repeal or weaken the exemption. Expressed support for H.R. 530, the Accelerating Broadband Development by Empowering Local Communities Act of 2019, to repeal the FCC's report and order that seeks to regulate public power pole attachments. Expressed support for S. 2012, the Restoring Local Control Over Public Infrastructure Act. Expressed opposition to S. 1699, the STREAMLINE Small Cell Deployment Act. Discussed H.R. 1421, the HANGUP Act, that would subject the federal government to liability under the Telephone Consumer Protection Act (TCPA) and how it could impact public power utilities. Discussed the FCCs open docket on automated telephone dialer systems (FCC CG Docket Nos. 18-152 and 02-278) and how it could impact public power utilities. Discussed public powers concerns with FCC proceeding to open the 6 GHz band to unlicensed users (FCC ET Docket No. 18-295 and GN Docket No. 17-183).
Discussed APPAs opposition to President Trumps fiscal year 2020 budget proposal to divest the transmission assets of the Power Marketing Administrations (PMAs) and Tennessee Valley Authority and to require the PMAs to charge market-based rates. Lobbied for increased funding to the Environmental Protection Agency for federal and state permitting programs for coal combustion residuals in fiscal year 2020.
Discussed how public power and Department of Homeland Security can collaborate on grid security matters. Discussed potential cyber vulnerabilities that could arise from the supply chain and the need to ensure equipment used on the electric grid is secure. Discussed potential ways to address third-party liability concerns during a grid security emergency. Discussed APPAs cooperative agreement with the Department of Energy (DE-OE-0000811), Improving the Cyber Resiliency and Security Posture of Public Power, and how APPA is using funding to work with its members to improve their cyber hygiene. Provided feedback on and support for H.R. 359, the Enhancing Grid Through Public-Private Partnerships Act, to permanently authorize program assisting small- and medium-sized electric utilities with grid security. Discussed the electric utility industry's efforts to protect the grid and its close work with the federal government on cyber and physical security through the Electricity Subsector Coordinating Council. Provided feedback and support for H.R. 2114, the State Energy Security Planning and Emergency Preparedness Act. Discussed FERC docket RM 18-09 and the need for state and local regulators to be able to consent to aggregation of DERs on distribution systems in their jurisdictions. Also discussed the particular burdens the proposed rule would have on small utilities. Discussed concerns about rising transmission costs and potential impact of FERC notices of inquiry on incentives and equity returns (Dkt. PL19-3 and PL 19-4). Discussed transmission planning policies under Orders No. 890 and No. 1000. Discussed RTO governance issues. Discussed support for the inclusion of language to improve the hydropower licensing and relicensing reform process in an energy title to an infrastructure bill or as stand-alone legislation. Discussed support for language in draft legislation to carve out federal hydropower facilities from the definition of eligible federal facilities that can use energy savings performance contracts. S. 1706/H.R. 3079 Discussed support for the inclusion of language in an energy title of an infrastructure bill to fund pilot projects on advanced distribution system management technologies. Discussed support for the inclusion of language to improve the siting of interstate natural gas pipelines in an energy title of an infrastructure bill. Discussed concerns with mandatory capacity markets in the Eastern RTOs and the need to ensure public powers ability to self-supply power in those markets. Discussed concerns with any proposed attempts by Congress to federalize rate design and how public power is working with its customers to enable distributed energy resources. Discussed S. 1760, the UPDATE PURPA Act. Discussed possible PURPA reform at Federal Energy Regulatory Commission. Discussed utility industry research on the potential impact to grid of an electromagnetic pulse. Provided feedback on energy storage legislation - S. 1602/H.R. 2986 and S. 1593/H.R. 1743 Discussed S. 1974, Renewable Electricity Standard Act.
Discussed what public power utilities are doing to reduce their greenhouse gas emissions and support for policies that would reduce emissions, such as energy efficiency, the promotion of hydropower and nuclear power, and the promotion of electric vehicles.
Discussed privacy legislation.
Filing targets: Bureau of Land Management (BLM), Energy, Dept of, Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), SENATE, U.S. Forest Service
Lobbied in support of repealing and replacing of Section 433 of Energy Independence and Security Act in draft legislation. Discussed electric vehicles and the development of charging infrastructure by public power utilities. Expressed support for S. 674, the Clean Corridors Act of 2019, and the inclusion of similar language in an infrastructure bill. Lobbied on the need for a permanent repository for spent nuclear waste. Discussed S. 903, the Nuclear Energy Leadership Act.
Discussed potential cyber vulnerabilities that could arise from the supply chain and the need to ensure equipment used on the electric grid is secure. Discussed APPAs cooperative agreement with the Department of Energy (DE-OE-0000811), Improving the Cyber Resiliency and Security Posture of Public Power, and how APPA is using funding to work with its members to improve their cyber hygiene. Provided feedback on and support for H.R. 359, the Enhancing Grid Through Public-Private Partnerships Act, to permanently authorize program assisting small- and medium-sized electric utilities with grid security. Discussed the electric utility industry's efforts to protect the grid and its close work with the federal government on cyber and physical security through the Electricity Subsector Coordinating Council. Provided feedback and support for H.R. 2114, the State Energy Security Planning and Emergency Preparedness Act. Provided feedback on draft legislation, the Grid Cybersecurity Research and Development Act, which would direct cyber research at the National Institute of Standards and Technology. Provided feedback on S. 881, the Space Weather Research and Forecasting Act, which would among other things safeguard infrastructure from space weather events. Discussed public powers concerns about rising transmission costs and the need for a proper determination about whether a project upgrade is actually needed. Discussed FERC docket RM 18-09 and the need for state and local regulators to be able to consent to aggregation of DERs on distribution systems in their jurisdictions. Also discussed the particular burdens the proposed rule would have on small utilities. Discussed developments in Western markets, including the impact of PG&Es bankruptcy on Western Market participants. Discussed support for the inclusion of language to improve the hydropower licensing and relicensing reform process in an energy title to an infrastructure bill or as stand-alone legislation. Discussed support for language in draft legislation to carve out federal hydropower facilities from the definition of eligible federal facilities that can use energy savings performance contracts. Discussed support for the inclusion of language in an energy title of an infrastructure bill to fund pilot projects on advanced distribution system management technologies. Discussed support for the inclusion of language to improve the siting of interstate natural gas pipelines in an energy title of an infrastructure bill. Discussed concerns with mandatory capacity markets in the Eastern RTOs and the need to ensure public powers ability to self-supply power in those markets. Discussed concerns with any proposed attempts by Congress to federalize rate design and how public power is working with its customers to enable distributed energy resources. Discussed support for H.R. 1502, the PURPA Modernization Act.
Discussed APPAs cooperative agreement with the Department of Energy (DE-OE-0000811), Improving the Cyber Resiliency and Security Posture of Public Power and how APPA is using funding to work with its members to improve their cyber hygiene. Requested continued funding for Cybersecurity for Energy Delivery Systems program in DOE's fiscal year 2020 budget. Discussed APPAs opposition to President Trumps fiscal year 2020 budget proposal to divest the transmission assets of the Power Marketing Administrations (PMAs) and Tennessee Valley Authority and to require the PMAs to charge market-based rates. Discussed public power support for adequate funding for the Low-Income Home Energy Assistance Program in fiscal year 2020. Lobbied for increased funding to the Environmental Protection Agency for federal and state permitting programs for coal combustion residuals in fiscal year 2020.
Filing targets: Bureau of Land Management (BLM), Energy, Dept of, Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Interior, Dept of (DOI), SENATE
Discussed EPA's proposed Affordable Clean Energy Rule, which would create carbon dioxide emissions standards for existing electric generating unit. EPA-HQ-OAR-2017-0355.
Lobbied in support of including repeal and replacement of Section 433 of Energy Independence and Security Act in S. 385 and H.R. 1443. Lobbied in support of various rebate programs in S. 1460, the Energy and Natural Resources Act of 2017. Discussed electric vehicles and the development of charging infrastructure by public power utilities. Lobbied on the need for a permanent repository for nuclear waste, including the development of Yucca Mountain. Discussed the Administration's efforts to use the Defense Production Act to support nuclear and coal-fired power plants.
Filing targets: Bureau of Land Management (BLM), Energy, Dept of, Environmental Protection Agency (EPA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, SENATE, U.S. Forest Service
Expressed support for H.R. 3128, legislation to amend the New Source Review provisions of the Clean Air Act.
Lobbied to preserve the municipal exemption in Section 224 of the Communications Act from federal pole attachment regulations. Expressed opposition to S. 3157, the STREAMLINE Small Cell Deployment Act, that would essentially gut public power's exemption from federal pole attachment regulations. Discussed concerns with proposed rules and notices of inquiry issued by the Federal Communications Commission on wireline and wireless broadband deployment. FCC No. 17-79, 17-84.
Discussed public power's support for modernizing the Endangered Species Act (ESA). Expressed support for H.R. 2083/S. 3119, the Endangered Salmon and Fisheries Predation Prevention Act, to protect ESA-listed fish species and ratepayers in the Pacific Northwest by addressing sea lion predation in the Columbia River Basin. Expressed support for H.R. 3144, to provide for operations of the Federal Columbia River Power System pursuant to a certain operation plan for a specified period of time, and for other purposes. Expressed support for H.R. 4465, the Endangered Fish Recovery Programs Extension Act of 2017, which extends programs that provide ESA-compliance for public power utilities in the Western U.S. Provided feedback on ESA reform legislation by Senator John Barrasso. Discussed the need for species protections to not be overly burdensome on public power utilities. Provided feedback on H.R. 6354, the STORAGE Act, to amend the ESA to prohibit the Departments of the Interior and Commerce from designating as critical habitat an area in a water storage, diversion, or delivery facility where habitat is periodically created and destroyed as a result of changes in water levels caused by the operation of the facility. Discussed how reviews conducted pursuant to the National Environmental Policy Act (NEPA) impact public power utilities and support for improving the NEPA implementation process.
Discussed support for provisions in H.R. 4, the FAA Reauthorization Act, that would facilitate the use of drones by electric utilities for routine maintenance and inspection of electric infrastructure and disaster recovery. Also discussed support for the provisions to create drone no-fly zones over critical electric infrastructure. Discusses the need for similar drone language in the Senate FAA reauthorization bill, S. 1405. Expressed support for the final FAA reauthorization bill, S. 302, which included provisions to enable the use of drones by electric utilities and to prevent the flying of drones over critical electric infrastructure.
Discussed the tax-exempt financing of public power infrastructure investments. Lobbied in support of H.R. 5003 to restore advance refunding bonds. Discussed potential ways to change private-use restrictions on municipal bonds. Discussed the need to extend energy tax incentives to tax-exempt entities. Discussed the issue of taxation of contributions in aid of construction.
Expressed opposition to the President's fiscal year (FY) 2019 proposal to divest the transmission assets of the Power Marketing Administrations (PMAs) and Tennessee Valley Authority (TVA) and to change PMA rates from cost based to market based. Lobbied in support of report language in to H.R. 5895, the Energy & Water Development Appropriations bill for fiscal year 2019, expressing opposition to the sale of the PMAs and/or TVA and their assets. Also supported language in the bill aimed at stopping the court-ordered spill on the Federal Columbia River Power System. Expressed opposition to the Administration's proposal to privatize the PMAs and TVA in its report on reorganizing and reforming the government. Provided feedback on draft legislation to establish a revolving fund at the Army Corps of Engineers for the Southwestern Power Administration. Expressed support for funding for restoration of Yucca Mountain as a permanent repository for spent nuclear fuel in H.R. 5895, the Energy & Water Development Appropriations Act for Fiscal Year 2019.
Filing targets: Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, SENATE
Discussed support for provisions in H.R. 4, the FAA Reauthorization Act, that would facilitate the use of drones by electric utilities for routine maintenance and inspection of electric infrastructure and disaster recovery. Also discussed support for the provisions to create drone no-fly zones over critical electric infrastructure. Discusses the need for similar drone language in the Senate FAA reauthorization bill, S. 1405.
Lobbied in support of funding for the Cybersecurity for Energy Delivery Systems program at the Department of Energy -- H.R. 1625, the Consolidated Appropriations Act, 2018. Expressed opposition to the President's FY 2019 proposal to divest the transmission assets of the Power Marketing Administrations (PMAs) and Tennessee Valley Authority and to change PMA rates from cost based to market based. Lobbied in support of an amendment to H.R. 5895, the Energy & Water Development Appropriations bill for fiscal year 2019, to prohibit the use of funds to carry out privatization of the PMAs and/or TVA. Expressed opposition to an amendment to H.R. 5895 that would reduce Western Area Power Administration Administrator Mark Gabriel's salary to $1 (Holman rule). Expressed opposition to the Administration's proposal to privatize the PMAs and TVA in its report on reorganizing and reforming the government. Expressed support for funding for restoration of Yucca Mountain as a permanent repository for spent nuclear fuel in H.R. 5895, the Energy & Water Development Appropriations Act for Fiscal Year 2019.
Provided feedback on and support for H.R. 5240, Enhancing Grid Through Public-Private Partnerships Act, to permanently authorize program assisting small- and medium-sized electric utilities with grid security. Provided feedback on H.R. 5239, Cyber Sense Act of 2018, to establish a volunteer program that identifies and promotes cyber-secure product intended for use in the bulk power system. Discussed the need for enhanced background screening of utility employees and provided feedback on draft legislation. Discussed support for legislation to improve the hydropower licensing and relicensing reform -- H.R. 3043 and provisions in S. 1460. Discussed language in H.R. 723/S. 239 that carves out federal hydropower facilities from the definition of eligible federal facilities that can use energy savings performance contracts. Discussed FERC policies on distributed energy resources -- FERC RM 16-23. Discussed FERC policies on use of tariffs in wholesale markets to promote bulk power grid resilience. Discussed support for H.R. 2910, legislation to expedite the permitting of interstate natural gas piplelines. Lobbied in support of wholesale electricity market reforms with focus on capacity markets and protecting customer interests, as well as ensuring public power's right to self-supply. Discussed concerns with any proposed attempts by Congress to federalize rate design and how public power is working with its customers to enable distributed energy resources. Discussed concerns with wholesale markets and FERC intrusion into energy matters that fall within state/local jurisdiction under the Federal Power Act. Lobbied on the need to protect public power and consumer interests in the potential expansion of the California ISO. Discussed FERC's order on grid resiliency -- FERC RM 18-1. Discussed implementation of vegetation management legislation, H.R. 1873, included in H.R. 1625, the Consolidated Appropriations Act, 2018, by the U.S. Forest Service and Bureau of Land Management. Lobbied in support of H.R. 587, the FAIR Rates Act. Discussed electric industry's close work with Canada on bulk power system issues.
Expressed support for draft legislation to amend the New Source Review provisions of the Clean Air Act. Expressed support for the Administrations efforts to repeal and replace both the Clean Power Plan and Waters of the U.S. rule.
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, SENATE, Transportation, Dept of (DOT)
Lobbied in support of funding for the Cybersecurity for Energy Delivery Systems program at the Department of Energy -- H.R. 1625, the Consolidated Appropriations Act, 2018. Expressed opposition to the President's FY 2019 proposal to divest the transmission assets of the Power Marketing Administrations (PMAs) and Tennessee Valley Authority and to change PMA rates from cost based to market based. Expressed opposition to including language on electromagnetic pulse in H.R. 1625, the Consolidated Appropriations Act, 2018.
Discussed efforts to restore power after Hurricane Maria. Discussed the mutual aid process for public power utilities.
Filing targets: Energy, Dept of, Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, SENATE
Discussed efforts to restore power after Hurricanes Harvey, Irma, and Maria. Discussed the mutual aid process for public power utilities. Expressed support for presidential granting of 100 percent reimbursement for category A and B costs for Puerto Rico in the aftermath of Hurricane Maria -- FEMA cost sharing for Notice of Major Disaster for the Commonwealth of PR (FEMA 4339-DR)
Discussed Cross State Air Pollution Rule. Discussed repeal of the Clean Power Plan -- Repeal of Carbon Dioxide Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units -- Docket ID: EPA-HQ-OAR-2017-0355
Lobbied to preserve the municipal exemption in Section 224 of the Communications Act from federal pole attachment regulations. Discussed concerns with proposed rules and notices of inquiry issued by the Federal Communications Commission on wireline and wireless broadband deployment. FCC No. 17-79, 17-84
Filing targets: Commodity Futures Trading Commission (CFTC), Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, SENATE
Discussed efforts to restore power after Hurricanes Harvey, Irma, and Maria. Discussed the mutual aid process for public power utilities. Expressed support for presidential granting of 100 percent reimbursement for category A and B costs for Puerto Rico in the aftermath of Hurricane Maria -- FEMA cost sharing for Notice of Major Disaster for the Commonwealth of PR (FEMA 4339-DR)
Lobbied in support of wholesale electricity market reforms with focus on capacity markets and protecting customer interests. Lobbied on the need to protect public power and consumer interests in the potential expansion of the California ISO. Discussed the importance of the electric utility industry and government partnership to share information and work together on grid security; discussed regulations on grid security; discussed industry efforts on the potential threat of electromagnetic pulse to the electric grid -- S.1519, H.R. 2910-- supporting modification of provisions regarding EMPs Discussed need for legislation to improve the hydropower licensing and relicensing reform, including support for H.R. 3043 and provisions in S. 1460. Discussed need for legislation to improve interstate natural gas pipeline permitting process, including support for H.R. 2910 and provisions in S. 1460. Discussed need for legislation on vegetation management and in support of H.R. 1873. Also support vegetation management language in S. 1460, Energy & Natural Resources Act of 2017. Lobbied in support of congressional oversight of the implementation of the Federal Power Act. Discussed issues related to distributed generation, including rate design and microgrids. Provided feedback on draft bills to promote distributed energy resources. Also provided feedback on S. 1874, Distributed Energy Demonstration Act of 2017, S. 1875, the Flexible Grid Infrastructure Act of 2017, and S. 1876, Reducing the Cost of Energy Storage Act of 2017. Discussed the need for enhanced background screening of utility employees. Discussed language in H.R. 723/S. 239 that carves out federal hydropower facilities from the definition of eligible federal facilities that can use energy savings performance contracts. Provided feedback on proposed legislation permanently authorizing program assisting small- and medium-sized utilities with grid security. Discussed needed reforms to the Public Utility Regulatory Policies Act of 1978. Discussed issues being examined in DOE study on grid reliability, including wholesale markets, renewables, and hydropower. Discussed the following dockets at FERC: -- State Policies and organized wholesale markets (FERC Dkt. AD17-11) -- Electric storage participation in RTO/ISO markets (FERC Dkt. RM16-23) -- FERC price formation dockets (FERC Dkt. RM17-03; RM17-20)
Lobbied in support of preserving the tax-exempt status of municipal bonds in any tax reform proposal and its importance for financing public power infrastructure.
Lobbied in support of H.R. 806, the Ozone Standards Implementation Act.
Filing targets: Energy, Dept of, Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), SENATE, White House Office
Lobbied to preserve the municipal exemption in Section 224 of the Communications Act from federal pole attachment regulations.
Lobbied in support of funding for Cybersecurity for Energy Delivery Systems program at the Department of Energy. Discussed opposition to fiscal year 2018 budget proposal from President that recommends selling the transmission assets of the Power Marketing Administrations. Lobbied in support of Power Marketing Administrations and TVA. Also discussed issues specific to the Western Area Power Administration.
Lobbied in support of preserving the tax-exempt status of municipal bonds in any tax reform proposal and its importance for financing public power infrastructure. Lobbied in support of legislation on the nuclear production tax credit -- H.R. 1551 and S. 666. Discussed how public power cannot receive renewable energy tax credits as not-for-profit entities and the need for comparable incentives. Discussed S. 1068, the Clean Energy for America Act. Discussed the impact of sequestration on Build America Bonds issued by public power.
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, SENATE, White House Office
Lobbied in support of preserving the tax-exempt status of municipal bonds in any tax reform proposal and its importance for financing public power infrastructure. Lobbied in support of legislation on the nuclear production tax credit -- H.R. 1551 and S. 666. Discussed how public power cannot receive renewable energy tax credits as not-for-profit entities and the need for comparable incentives.
Lobbied to preserve the municipal exemption in Section 224 of the Communications Act from federal pole attachment regulations.
Lobbied in support of H.R. 806, the Ozone Standards Implementation Act. Lobbied in support of Clean Air Act reform.
Lobbied to ensure that Congress considers impact of drone regulations on electric utilities in reauthorization of Federal Aviation Administration.
Lobbied in support of funding for Cybersecurity for Energy Delivery Systems program at the Department of Energy. Discussed potential for new fiscal year 2018 budget proposal from President to recommend privatizing Tennessee Valley Authority (TVA) and to sell Power Marketing Administrations. Lobbied in support of Power Marketing Administrations and TVA. Lobbied in support of funding for Low Income Home Energy Assistance Program in H.R. 5926 and S. 3040, the Departments of Labor, Health and Human Services, and Education, and Related Agencies Appropriations Act, 2017.
Filing targets: Energy, Dept of, Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, SENATE
Supported bills to ensure regulatory relief for hydro facilities. Supported language in the House and Senate energy bills to streamline hydro and relicensing for all sites of hydro facilities. Discussed the issue of mandatory conditioning during the hydropower licensing/relicensing process. Discussed the impact of language in H.R. 5303/S. 2848 regarding changes to reservoir operation manuals and allocation of costs at federal hydropower facilities. Discussed the need for oversight of energy efficiency standards
Filing targets: Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, SENATE
Discussed the need to monitor implementation of H.R. 2029, the Cybersecurity Act of 2015, and H.R. 22, the Fixing Americas Surface Transportation Act. Provided feedback on the provisions in H.R. 6227, the Grid Cybersecurity Research and Development Act. Discussed issues of importance to public power in S. 2012, the Energy Policy Modernization Act of 2016 (House and Senate versions), including provisions on capacity markets, grid security, grid modernization, distributed generation, energy efficiency, hydropower licensing reform, pipeline permitting, reliability, vegetation management, and geomagnetic disturbances/electromagnetic pulses. Lobbied in support of House and Senate going to conference. Discussed issues surrounding distributed generation and concerns with attempts to federalize what is a state/local jurisdictional issue. Expressed concerns about regional transmission organizations markets, including a proposed energy imbalance market and existing mandatory capacity markets. Encouraged oversight of FERC more generally and how the Federal Power Act is being implemented. Lobbied in support of protecting consumers interests in regional transmission organizations and independent system operator markets. Discussed implications of the expansion of the California ISO in the West for public power utilities.
Expressed support for efforts to update the Endangered Species Act. Expressed support for S. 2446, the Improving Coal Combustion Residuals Regulation Act of 2016 and House companion legislation -- H.R. 1734, the Improving Coal Combustion Residuals Regulation Act of 2015. Expressed support for the inclusion of coal ash legislation in the Senate Water Resources Development Act bill, S. 2848.
Expressed concerns with provisions in draft broadband infrastructure bill regarding pole attachment and their potential impact on public power.
Filing targets: Energy, Dept of, Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, SENATE
Discussed the need to monitor implementation of H.R. 2029, the Cybersecurity Act of 2015, and H.R. 22, the Fixing Americas Surface Transportation Act. Discussed issues of importance to public power in H.R. 8, the North American Energy Security and Infrastructure Act of 2015, including provisions on capacity markets, grid security, distributed generation, energy efficiency, hydropower licensing reform, pipeline permitting, reliability, and geomagnetic disturbances/electromagnetic pulses. Discussed issues of importance to public power in S. 2012, the Energy Policy Modernization Act of 2015, including provisions on capacity markets, grid security, distributed generation, energy efficiency, hydropower licensing reform, pipeline permitting, and reliability. Lobbied in support of S. 2012. Discussed issues surrounding distributed generation and concerns with attempts to federalize what is a state/local jurisdictional issue. Advocated on the need for small utilities that are defined as small businesses under the Small Business Regulatory Enforcement Fairness Act to get appropriate consideration under any pending and future EPA and FERC regulations. Worked to ensure that S. 1536, the Senate companion bill to H.R. 527, includes language to fix Small Business Administration size standard issue. Expressed concerns about regional transmission organizations markets, including a proposed energy imbalance market and existing mandatory capacity markets. Encouraged oversight of FERC more generally. Advocated in favor of H.R 2984, the Fair RATES Act re: FERC regulations. Discussed DOEs Quadrennial Energy Review 1.2. Lobbied on S. 1846, the Critical Infrastructure Act of 2016/H.R. 1073, to amend the Homeland Security Act of 2002 to secure critical infrastructure against electromagnetic threats, and for other purposes. Sought to preserve the current NERC-FERC model for grid security regulations. Lobbied in support of protecting consumers interests in regional transmission organizations and independent system operator markets. Discussed implications of the expansion of the California ISO in the West for public power utilities.
Lobbied in support of environmental riders to H.R. 5055, Energy & Water Development and Related Agencies Appropriations Act, 2017.
Discussed APPAs comments to EPA on its proposed Federal Plan and model trading rule (EPA-HQ-OAR-2013-0602). Also discussed the impact of the final Clean Power Plan on public power. Expressed support for H.R. 4775, the Ozone Standards Implementation Act of 2016.
Lobbied on provisions in H.R. 527/S.1536, the Regulatory Flexibility Improvements Act regarding definition of small governmental entities.
Supported bills to ensure regulatory relief for hydro facilities. Supported language in the House and Senate energy bills to streamline hydro and relicensing for all sites of hydro facilities. Discussed the need for DOE funding of small modular nuclear reactors. Discussed the issue of mandatory conditioning during the hydropower licensing/relicensing process. Lobbied on H.R. 2898, the Western Water and American Food Security Act of 2015, and S. 1894, the California Emergency Drought Relief Act of 2015, on the allocation of costs at federal hydropower facilities. Lobbied on provisions in the Water Resources Development Act of 2016 (S. 2848 and H.R. 5303)on the allocation of costs at federal hydropower facilities. Lobbied on the implications of how DOE calculates its source-site factor on public power(DE-FOA-00015812).
Expressed support for efforts to update the Endangered Species Act. Expressed support for S. 2446, the Improving Coal Combustion Residuals Regulation Act of 2016 and House companion legislation -- H.R. 1734, the Improving Coal Combustion Residuals Regulation Act of 2015. Advocated in support of H.R. 2576 and S. 697 to update the Toxic Substance Control Act.
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), Federal Aviation Administration (FAA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), SENATE, Surface Transportation Board (STB)
Discussed APPAs comments to EPA on its proposed Federal Plan and model trading rule (EPA-HQ-OAR-2013-0602). Also discussed the impact of the final Clean Power Plan on public power, and concerns regarding the final ozone rule. Opposed to EPA's final Waters of the U.S. rule under the Clean Water Act. Supported S.J. Res. 22, disapproval of the Waters of the U.S. rule under the Clean Water Act.
Expressed concerns with provisions in draft broadband infrastructure bill regarding pole attachment and their potential impact on public power.
Supported bills to ensure regulatory relief for hydro facilities. Supported language in the House and Senate energy bills development to streamline hydro and relicensing for all sites of hydro facilities. Monitored agency implementation of hydro bills that passed in the 113th Congress (H.R. 678, H.R. 267). Discussed Nuclear Regulatory Commission (NRC) and nuclear waste issues. Discussed the need for DOE funding of small modular nuclear reactors. Discussed the issue of mandatory conditioning during the hydropower licensing/relicensing process.
Discussed the need to monitor implementation for H.R. 2029, the Cybersecurity Act of 2015, and H.R. 22, the Fixing Americas Surface Transportation Act. Discussed issues of importance to public power in H.R. 8, the North American Energy Security and Infrastructure Act of 2015, including provisions on capacity markets, cybersecurity, distributed generation, energy efficiency, hydropower licensing reform, pipeline permitting, reliability. Discussed issues of importance to public power in S. 2012, the Energy Policy Modernization Act of 2015, including provisions on capacity markets, cybersecurity, distributed generation, energy efficiency, hydropower licensing reform, pipeline permitting, reliability, geomagnetic disturbances/electromagnetic pulses, and emergency coal fuel supplies. Lobbied in support of S. 2012. Opposed amendments to federalize distributed generation. Supported amendments to modify or eliminate Section 1222 of EPAct05. Expressed support for the inclusion of language to ensure the ability of public power to self-supply in S. 2012. Advocated on the need for small utilities that are defined as small businesses under the Small Business Regulatory Enforcement Fairness Act to get appropriate consideration under any pending and future EPA and FERC regulations. Worked to ensure that S. 1536, the Senate companion bill to H.R. 527, includes language to fix Small Business Administration size standard issue. Expressed concerns about regional transmission organizations markets, including a proposed energy imbalance market and existing mandatory capacity markets. Encouraged oversight of FERC more generally. Discussed issues surrounding distributed generation and concerns with attempts to federalize what is a state/local jurisdictional issue. Expressed support for S. 485, the APPROVAL ACT, Assuring Private Property Rights Over Vast Access to Land Act. Advocated in favor of H.R 2984, the Fair RATES Act re: FERC regulations. Discussed DOEs Quadrennial Energy Review 1.2. Reviewed and provided feedback to Senate Commerce Committee staff on a discussion draft re: space weather.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Federal Aviation Administration (FAA), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), SENATE, Treasury, Dept of, White House Office
Supported the continued use of tax-exempt financing for municipal/public power purposes, and opposed provisions and legislation to tax municipal bonds. Monitored impacts of sequestration on Build America Bonds (BABs).
Advocated for passage of information sharing legislation such as the S. 754, Cybersecurity Information Sharing Act of 2015, H.R. 1560, the Protecting Cyber Networks Act, and H.R. 1731, the National Cybersecurity Protection Advancement Act of 2015. Advocated for public power language in conference committee and supported cybersecurity bill in omnibus appropriations bill. Discussed the need for enhanced liability protection for electric utilities that are subject to a cybersecurity attack. Supported H.R. 22, the Fixing Americas Surface Transportation Act. Advocated for grid security provisions from H.R. 8 to be included in this bill once the amendment was filed; negotiated with House and Senate to retain in H.R. 22. Opposed H.R. 1073, the Critical Infrastructure Protection Act, S. 1241, the Enhanced Grid Security Act of 2015, and S.1846, a bill to amend the Homeland Security Act of 2002 to secure critical infrastructure against electromagnetic threats, and for other purposes. S. 720, the Energy Savings and Industrial Competitiveness Act of 2015 and H.R. 873, a bill to promote energy efficiency, and for other purposes. Discussed potential comprehensive energy legislation with House and Senate staff. Supported efforts to delete Section 433 of EISA 2007 of S. 869, which mandates that all federal buildings use no fossil fuel by 2030. Advocated for specific positions to be included in H.R. 8, the North American Energy Security and Infrastructure Act of 2015, which has provisions on capacity markets, cybersecurity, distributed generation, energy efficiency, hydropower licensing reform, pipeline permitting, and reliability. Opposed certain distributed generation/PURPA amendments to H.R. 8 during floor consideration. Also, advocated on similar issues in S. 2012, the Energy Policy Modernization Act of 2015. Continued working to ensure that small utilities that are defined as small businesses under the Small Business Regulatory Enforcement Fairness Act get appropriate consideration under any pending and future EPA and FERC regulations. Worked to ensure that S. 1536, the Senate companion bill to H.R. 527, which modified the Regulatory Flexibility Act, included language to fix Small Business Administration size standard issue. Expressed support for H.R. 2358, the Electricity Reliability and Forest Protection Act, that was approved by the House Committee on Natural Resources. Expressed concerns about or opposition to markets issues related to regional transmission organizations, including proposed energy imbalance market and existing mandatory capacity markets. Encouraged oversight of FERC more generally. While not a federal issue, discussed issues surrounding distributed generation (namely, rooftop solar) with DOE staff and with some offices on Capitol Hill such that it remains at state/local issue. Discussed the issue of the availability of spare transformers with DOE and others. Expressed support for S. 485, the APPROVAL ACT, Assuring Private Property Rights Over Vast Access to Land Act.
Supported bills to ensure regulatory relief for hydro facilities. Supported legislation in the House and Senate energy bills development to streamline hydro and relicensing for all sites of hydro facilities. Supported a hydro amendment to H.R.8, the North American Energy Security and Infrastructure Act of 2015, on hydropower licensing/relicensing reform. Monitored agency implementation of hydro bills that passed in the 113th Congress (H.R. 678, H.R. 267). Monitored Nuclear Regulatory Commission (NRC) and nuclear waste issues (S. 854: Nuclear Waste Administration Act of 2015).
Supported removal of the antitrust exemptions for the railroads, and supported reforms at the Surface Transportation Board in order to ensure that rail customers are not the subject of monopoly shipping rates. Advocated for passage of S. 808 Surface Transportation Board Re-authorization Act of 2015, which passed the House and signed into law. Monitored S. 853, the Rail Shipper Fairness Act of 2015.
Monitored efforts in Congress to address abuse of the patent system by patent assertion entities (PAEs), commonly known as patent trolls. Worked to ensure legislation is introduced to address patent assertion entities. Supported S. 1137, the PATENT Act that targets abusive patent ligation practices and supported H. R. 9, the Innovation Act.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Federal Aviation Administration (FAA), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), SENATE, Treasury, Dept of, White House Office
Support removal of the antitrust exemptions for the railroads, and support reforms at the Surface Transportation Board in order to ensure that rail customers are not the subject of monopoly shipping rates. Advocated for passage of S. 808 Surface Transportation Board Re-authorization Act of 2015, which passed the Senate without amendment. Monitored S. 853, the Rail Shipper Fairness Act of 2015.
Supported the continued use of tax-exempt financing for municipal/public power purposes, and opposed provisions and legislation to tax municipal bonds. Monitored impacts of sequestration on Build America Bonds (BABs).
Supported legislation (H.R. 1734, the Improving Coal Combustion Residuals Regulation Act of 2015) re: EPA regulation of coal ash as a non-hazardous waste, which passed out of the House on July 22. Expressed strong concerns on EPA's proposed Clean Power Plan and the impact on public power. Relayed our concerns on docket EPA-HQ-OAR-2013-0602. Also, discussed our concerns regarding ozone NAAQS rules. Opposed to EPA's proposed Waters of the U.S. rule under the Clean Water Act. Supported S. 1140, the Federal Water Quality Protection Act, which passed out of the Senate Environment and Public Works Committee. Expressed support for H.R. 2042, the Ratepayer Protection Act, and companion legislation S. 1324, the Affordable Reliable Electricity Now Act of 2015. Monitored H.R. 2576, the House of Representatives update to the Toxic Substance Control Act and advocated for passage in the House and Senate.
Monitored information sharing legislation such as the S. 754, Cybersecurity Information Sharing Act of 2015, H.R. 1560, the Protecting Cyber Networks Act, and H.R. 1731, the National Cybersecurity Protection Advancement Act of 2015. Discussed the need for enhanced liability protection for electric utilities that are subject to a cybersecurity attack. Opposed to H.R. 1073, the Critical Infrastructure Protection Act, S. 1241, the Enhanced Grid Security Act of 2015, and S.1846, a bill to amend the Homeland Security Act of 2002 to secure critical infrastructure against electromagnetic threats, and for other purposes. Continued support of revised energy efficiency legislation - S. 535, the Energy Efficiency Improvement Act of 2015, S. 720, the Energy Savings and Industrial Competitiveness Act of 2015, H.R. 906, a bill to modify the efficiency standards for grid-enabled water heaters, and H.R. 873, a bill to promote energy efficiency, and for other purposes. Discussed potential comprehensive energy legislation with House and Senate staff. Supported efforts to delete Section 433 of EISA 2007 of S. 869. which mandates that all federal buildings use no fossil fuel by 2030. Advocated for specific positions to be included in H.R. 8, the North American Energy Security and Infrastructure Act of 2015, that included provisions on capacity markets, cybersecurity, distributed generation, energy efficiency, hydropower licensing reform, pipeline permitting, reliability, self-supply, wholesale energy markets, and workforce development. Also, advocated for positions to be included in the drafting process of S. 2012, the Energy Policy Modernization Act of 2015. APPA supports underlying emergency authority sections in both bills, but think cost-recovery is duplicative and unnecessary. APPA believes states need preemption from sunshine law application to targeted critical infrastructure information. APPA supports FERC review of reliability implications of major rules. APPA supports streamlining of hydropower licensing reform processes. APPA opposes codification of PJM performance capacity rules. APPA supports provisions to ensure public powers ability to self-supply its own customers. APPA supports pipeline permitting reform and workforce development provisions. Continued working to ensure that small utilities that are defined as small businesses under the Small Business Regulatory Enforcement Fairness Act get appropriate consideration under any pending and future EPA and FERC regulations. Worked to ensure that S. 1536, the Senate companion bill to H.R. 527, which modified the Regulatory Flexibility Act, included language to fix Small Business Administration size standard issue. Expressed support for H.R. 2358, the Electricity Reliability and Forest Protection Act that was approved by the House Committee on Natural Resources. Expressed concerns about or opposition to markets issues related to regional transmission organizations, including proposed energy imbalance market and existing mandatory capacity markets. Encouraged oversight of FERC more generally. While not a federal issue, discussed issues surrounding distributed generation (namely, rooftop solar) with DOE staff and with some offices on Capitol Hill. Discussed the issue of the availability of spare transformers with DOE and others. Expressed support for S. 485, the APPROVAL ACT, Assuring Private Property Rights Over Vast Access to Land Act. Advocated for SEPA rate proposal regarding cost allocation at the Center Hill and Wolf Creek dams. Provisions related to cost allocation of federally-owned dams. Monitored Southeastern Federal Power Administration Rate making procedures.
Monitored efforts in Congress to address abuse of the patent system by patent assertion entities (PAEs), commonly known as patent trolls. Worked to ensure legislation is introduced to address patent assertion entities. Supported S. 1137, the PATENT Act that targets abusive patent ligation practices and supported H. R. 9, the Innovation Act.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Federal Aviation Administration (FAA), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), SENATE, Treasury, Dept of, White House Office
Expressed concerns about or opposition to markets issues related to regional transmission organizations, including proposed energy imbalance market and existing mandatory capacity markets. Encouraged oversight of FERC more generally. Continued support of revised Senate energy efficiency bill, S. 535, H.R. 906, H.R. 873 and S. 720 Discussed potential legislation to ensure that federal agencies take electric reliability into consideration when developing regulations. Discussed potential comprehensive energy legislation with House and Senate staff. Continued working to ensure small utilities that are defined as small businesses under SBREFA get appropriate consideration under any pending and future EPA and FERC regulations. Worked to ensure that S. 1536, the Senate companion bill to H.R. 527, which modified the Regulatory Flexibility Act included language to fix SBA size standard issue. Supported efforts to delete Section 433 of EISA 2007, which mandates that all federal buildings use no fossil fuel by 2030. While not a federal issue, discussed issues surrounding distributed generation (namely, rooftop solar) with DOE staff and with some offices on Capitol Hill. Discussed the Quadrennial Energy Review (and its focus on distribution, transmission and storage of energy) with DOE and the White House and submitted statements and other materials related to that process. Discussed the need for enhanced liability protection for electric utilities who are subject to a cybersecurity attack. Briefed Senate and House staff on the physical security of the electric system, and opposed additional legislation resulting in greater regulation. Discussed the issue of the availability of spare transformers with DOE and others. Monitored information sharing legislation such as Cybersecurity Information Sharing Act of 2015, S. 754, H.R. 1560, the Protecting Cyber Networks Act, H.R. 1731, the National Cybersecurity Protection Advancement Act of 2015. Expressed support for Pompeo pipeline permitting bill - H.R. 161, which passed the House. Expressed support for H.R. 2358, the Electricity Reliability and Forest Protection Act. Expressed support for H.R. 1073, the Critical Infrastructure Protection Act and S. 1241, the Enhanced Grid Security Act of 2015. Monitored Southeastern Federal Power Administration Rate making procedures. Heavily engaged in pending House energy bill discussion draft on topics that include FERCs role in reviewing rule makings with significant impact on reliability; emergency authority to bulk power systems; hydro relicensing reform; and energy markets issues. In the Senate, also engaged in energy bill process, with specific positions on pending bills included below. S. 1221, the Bulk-Power System Reliability Impact Statement Act Expressed opposition to S. 1233, the PURPA PLUS Act, S. 1264, the Electricity Standard Act, S. 1434, the Energy Storage Promotion and Deployment Act of 2015, S. 1213, the Free Market Energy Bill Act of 2015. Expressed opposition to S. 1063, the American Energy Efficiency Act and S. 1202, the Heat Efficiency through Applied Technology Act. Supported S. 1405, the Severe Fuel Supply Emergency Response Act of 2015.
Monitored the issue of "retransmission consent" with regard to access to cable programming. Also monitored the issues of program access and video competition. Monitored pole attachment rate issue. Support municipal broadband deployment, and educated House and Senate staff these issues.
Monitored efforts in Congress to address abuse of the patent system by patent assertion entities (PAEs), commonly known as patent trolls. Worked to ensure legislation is introduced to address patent assertion entities. Supported S. 1137, the PATENT Act that targets abusive patent ligation practices.
Supported the continued use of tax-exempt financing for municipal/public power purposes, and opposed provisions and legislation to tax municipal bonds. Monitored impacts of sequestration on Build America Bonds (BABs). Expressed support for S. 485, the APPROVAL ACT, Assuring Private Property Rights Over Vast Access to Land Act.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Federal Aviation Administration (FAA), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), SENATE, Treasury, Dept of, White House Office
Supported the continued use of tax-exempt financing for municipal/public power purposes, and opposed provisions and legislation to tax municipal bonds. Monitored impacts of sequestration on Build America Bonds (BABs).
Monitored efforts in Congress to address abuse of the patent system by patent assertion entities (PAEs), commonly known as patent trolls.
Expressed concerns about or opposition to markets issues related to regional transmission organizations, including proposed energy imbalance market and existing mandatory capacity markets. Encouraged oversight of FERC more generally. Monitored issues related to electric vehicles, particularly regarding funding issues. Continued support of revised Senate energy efficiency bill, S. 535, H.R. 906, H.R. 873 and S. 720 Discussed potential legislation to ensure that federal agencies take electric reliability into consideration when developing regulations. Discussed potential comprehensive energy legislation with House and Senate staff. Worked to ensure small utilities that are defined as small businesses under SBREFA get appropriate consideration under any pending and future EPA and FERC regulations. Monitored H.R. 527, which modified the Regulatory Flexibility Act and passed the House. Supported efforts to delete Section 433 of EISA 2007, which mandates that all federal buildings use no fossil fuel by 2030. While not a federal issue, discussed issues surrounding distributed generation (namely, rooftop solar) with DOE staff and with some offices on Capitol Hill. Discussed the Quadrennial Energy Review (and its focus on distribution, transmission and storage of energy) with DOE and the White House and submitted statements and other materials related to that process. Discussed the need for enhanced liability protection for electric utilities who are subject to a cybersecurity attack. Briefed Senate and House staff on the physical security of the electric system, and opposed additional legislation resulting in greater regulation. Discussed the issue of the availability of spare transformers with DOE and others. Monitored information sharing legislation such as Cybersecurity Information Sharing Act of 2015, S. 754. Expressed support for Pompeo pipeline permitting bill - HR 161, which passed the House
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Federal Aviation Administration (FAA), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), SENATE, Treasury, Dept of, White House Office
Support legislation (H.R. 2218) re: EPA regulation of coal ash as a non-hazardous waste. Opposed to EPA's proposed rulemaking on a New Source Performance Standard (NSPS) for greenhouse gases at future fossil-fuel fired power plants, and do not believe CCS adequately demonstrated (EPAOAR-20130495). Opposed to EPA proposed rulemaking on NSPS for existing power plants (EPAHQOAR20130602), and briefed House Science Committee members and staff on state perspectives on the issue.Opposed to EPA's proposed Waters of the U.S. rule under the Clean Water Act (EPA-HW-OW-2011-0880. Supported H.R. 5078, Waters of the United States Regulatory Protection Act, which passed the House.Supported Whitfield-Manchin bill (H.R. 3826) to establish a more rigorous process for EPA to be able to establish NSPS for greenhouse gas emissions. Support H.R. 1900 related to Natural Gas Pipeline Permitting Reform Act. Monitored Water Resources Development Act (WRDA/WRDDA) implementation, with emphasis on U.S. Army Corps of Engineers reform and dam safety.
Supported the continued use of tax-exempt financing for municipal/public power purposes, and opposed provisions, like those included in the Administration's FY 2015 budget proposal, to tax municipal bonds. Supported H. Res. 112, highlighting the value of tax-exempt financing, and authored by Reps. Terry and Neal. Monitored impacts of sequestration on Build America Bonds (BABs), including H.R. 789 and H.J.Res. 59.Monitored the Tax Reform Act of 2014 (not introduced) for proposals to tax interest paid on municipal bonds.
Monitored efforts in Congress to address abuse of the patent system by patent assertion entities (PAEs), commonly known as patent trolls.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), Office of Management & Budget (OMB), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office
Expressed concerns about or opposition to markets issues related to regional transmission organizations, including proposed energy imbalance market and existing mandatory capacity markets. Encouraged oversight of FERC more generally. Monitored issues related to electric vehicles, particularly regarding funding issues. Continued support of revised Senergy efficiency bill, S. 1392Worked to ensure small utilities that are defined as small businesses under SBREFA get appropriate consideration under any pending and future EPA and FERC regulations. Supported H.R. 2542, which modified the Regulatory Flexibility Act and passed the House. Supported Senator Klobuchar bill related to preventing copper theft. Support H.R. 1199 to delete Section 433 of EISA 2007, which mandates that all federal buildings use no fossil fuel by 2030. Also support other efforts to fix this issue. Support S. 2620, the Grid Reliability Act of 2014 (companion bill to H.R. 271.) While not a federal issue, discussed issues surrounded distributed generation (namely, rooftop solar) with DOE staff. Discussed the Quadrennial Energy Review (and it's focus on distribution, transmission and storage of energy) with DOE and the White House and submitted statements and other materials related to that process. Discussed the need for enhanced liability protection for electric utilities who are subject to a cybersecurity attack. Briefed Senators and House Members and staff on the physical security of the electric system, and opposed additional legislation resulting in greater regulation. Discussed the issue of the availability of spare transformers with DOE and others. Support information sharing legislation such as CISPA, H.R. 3523, and the Cybersecurity Information Sharing Act of 2014, S. 2588. Supported cybersecurity related bills S. 2519 and S. 1353.
Monitored efforts in Congress to address abuse of the patent system by patent assertion entities (PAEs), commonly known as patent trolls.
Supported the continued use of tax-exempt financing for municipal/public power purposes, and opposed provisions, like those included in the Administration's FY 2015 budget proposal, to tax municipal bonds. Supported H. Res. 112, highlighting the value of tax-exempt financing, and authored by Reps. Terry and Neal. Monitored impacts of sequestration on Build America Bonds (BABs), including H.R. 789 and H.J.Res. 59.Monitored the Tax Reform Act of 2014 (not introduced) for proposals to tax interest paid on municipal bonds.
Monitored the issue of "retransmission consent" with regard to access to cable programming. Also monitored the issues of program access and video competition. Monitored pole attachment rate issue. Support municipal broadband deployment, and educated House Telecommunications Subcommittee on these issues as they begin to rewrite the Telecommunications Act of 1996.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), Office of Management & Budget (OMB), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office
Support legislation (H.R. 2218) re: EPA regulation of coal ash as a non-hazardous waste. Opposed to EPA's proposed rulemaking on a New Source Performance Standard (NSPS) for greenhouse gases at future fossil-fuel fired power plants, and do not believe CCS adequately demonstrated (EPAOAR-20130495). Opposed to EPA proposed rulemaking on NSPS for existing power plants (EPAHQOAR20130602). Opposed to EPA's proposed Waters of the U.S. rule under the Clean Water Act.Supported Whitfield-Manchin bill (H.R. 3826) to establish a more rigorous process for EPA to be able to establish NSPS for greenhouse gas emissions. Support H.R. 1900 related to Natural Gas Pipeline Permitting Reform Act. Monitored Water Resources Development Act (WRDA/WRDDA) progress, with emphasis on U.S. Army Corps of Engineers reform and dam safety. Opposed Section 2014 of Senate version of WRDA bill, S. 601. Supported section 1046 of the final version of WRRDA, as passed and signed into law.
Supported the continued use of tax-exempt financing for municipal/public power purposes, and opposed provisions, like those included in the Administration's FY 2015 budget proposal, to tax municipal bonds. Support H. Res. 112, highlighting the value of tax-exempt financing, and authored by Reps. Terry and Neal. Monitored impacts of sequestration on Build America Bonds (BABs), including H.R. 789 and H.J.Res. 59.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), Office of Management & Budget (OMB), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office
Monitored the issue of "retransmission consent" with regard to access to cable programming. Also monitored the issues of program access and video competition. Monitored pole attachment rate issue. Support municipal broadband deployment, and began to engage with House Telecommunications Subcommittee as they look at development of a broad telecommunications bill beginning this year.
Expressed concerns about or opposition to markets issues related to regional transmission organizations, including proposed energy imbalance market and existing mandatory capacity markets (FERC docket # AD 13-7). Encouraged oversight of FERC more generally. Monitored development of executive order on cyber security and engaged in NIST process, and supported final product. Monitored issues related to electric vehicles, particularly regarding funding issues. Support revised Senergy efficiency bill, S. 1392,pending on Senate floor. Monitor rulemakings related to transmission policy, and support FERC's decision to revise its transmission rate incentives policy (docket # RM 13-18). Worked to ensure small utilities that are defined as small businesses under SBREFA get appropriate consideration under any pending and future EPA and FERC regulations, and support H.R. 2542 to modify the Regulatory Flexibility Act. Supported Senator Klobuchar bill related to preventing copper theft. Support H.R. 1199 to delete Section 433 of EISA 2007, which mandates that all federal buildings use no fossil fuel by 2030. Also support other efforts to fix this issue. While not a federal issue, discussed issues surrounded distributed generation (namely, rooftop solar) with DOE staff. Discussed the process surrounding the pending Quadrennial Energy Review with DOE and the White House. Discussed the need for enhanced liability protection for electric utilities who are subject to a cyber-security attack. Briefed Senators and House Members on the physical security of the electric system, and opposed additional legislation resulting in greater regulation. Support information sharing legislation such as CISPA, H.R. 3523. Supported the SMART GRID Study Act, H.R. 2962. Discussed with DOE an alternative information sharing program for public power utilities.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), Office of Management & Budget (OMB), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office
Monitored the issue of "retransmission consent" with regard to access to cable programming. Monitored pole attachment rate issue. Support municipal broadband deployment, and began to engage with House Telecommunications Subcommittee as they geared up to being looking at development of a broad telecommunications bill in 2014.
Expressed concerns about or opposition to markets issues related to regional transmission organizations, including proposed energy imbalance market and existing mandatory capacity markets; encouraged oversight of FERC more generally; monitored development of executive order on cyber security and engaged in NIST process; monitored issues related to electric vehicles, particularly regarding funding issues. Support revised Shaheen-Portman energy efficiency bill, S. 1392, pending on Senate floor.Monitor rulemakings related to transmission policy. Worked to ensure small utilities that are defined as small businesses under SBREFA get appropriate consideration under any pending and future EPA and FERC regulations, and support H.R. 2542 to modify the Regulatory Flexibility Act. Supported Senator Klobuchar bill related to preventing copper theft. Support H.R. 1199 to delete Section 433 of EISA 2007, which mandates that all federal buildings use no fossil fuel by 2030. Also support other efforts to fix this issue. While not a federal issue, discussed issues surrounded distributed generation (namely, rooftop solar) with DOE staff.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), Office of Management & Budget (OMB), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office
Supported the continued use of tax-exempt financing for municipal/public power purposes, and opposed provisions, like those included in the Administration's FY 2014 budget proposal, to tax municipal bonds. Support H. Res. 112, highlighting the value of tax-exempt financing, and authored by Reps. Terry and Neal. Monitored impacts of sequestration on Build America Bonds (BABs). Opposed S.Con.Res. 8 because of proposal that could lead to limiting tax-exempt financing.
Supported legislation (H.R. 2218) re: EPA regulation of coal ash as a non-hazardous waste. Expressed concerns about parameters of effluent limitation guidelines under the Clean Water Act, pending at EPA. Concerned about air regulations on power plants being promulgated by EPA, including utility MACT (MATS). Concerned with EPA's proposed rulemaking on NSPS for greenhouse gases at future fossil-fuel fired power plants. Continue to discuss the electricity/natural gas nexus with Congress, FERC, & EPA.Monitored Water Resources Development Act (WRDA) progress, with emphasis on U.S. Army Corps of Engineers reform and dam safety. Oppose Section 2014 of Senate version of WRDA bill, S. 601. Support House version of WRRDA, H.R. 3080. Support H.R. 271, Olson reliability bill.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), Office of Management & Budget (OMB), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office
Expressed concerns about or opposition to markets issues related to regional transmission organizations, including proposed energy imbalance market and existing mandatory capacity markets; reviewed draft of Senate Commerce Committee cyber bill; monitored development of executive order on cyber security and responded to NIST request for information; monitored issues related to electric vehicles, particularly regarding funding issues. Monitored development of revised Portman-Shaheen energy efficiency bill.Monitor rulemakings related to transmission policy. Worked to ensure small utilities that are defined as small businesses under SBREFA get appropriate consideration under any pending and future EPA and FERC regulations, and support H.R. 527 to modify the Regulatory Flexibility Act. Interfaced with DOE and DHS on recovery and resilience, as recommended by the National Infrastructure Advisory Committee (NIAC), and in handling Hurricane Sandy recovery. Supported Senator Klobuchar bill related to preventing copper theft. Supported efforts to delete or fix Section 433 of EISA 2007, which mandates that all federal buildings use no fossil fuel by 2030.
Supported legislation (H.R. 2218) re: EPA regulation of coal ash as a non-hazardous waste. Expressed concerns about parameters of effluent limitation guidelines under the Clean Water Act, pending at EPA. Concerned about air regulations on power plants being promulgated by EPA, including utility MACT (MATS). Monitored EPA's pending rulemakings on NSPS for greenhouse gases at future and existing fossil-fuel fired power plants. Continue to discuss the electricity/natural gas nexus with Congress, FERC, & EPA.Monitored Water Resources Development Act (WRDA) progress, with emphasis on U.S. Army Corps of Engineers reform and dam safety. Supported H.R. 271, Olson reliability bill.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), Office of Management & Budget (OMB), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office
Supported the continued use of tax-exempt financing for municipal/public power purposes, and opposed provisions, like those included in the Administration's FY 2014 budget proposal, to tax municipal bonds. Support H. Res. 112, highlighting the value of tax-exempt financing, and authored by Reps. Terry and Neal. Monitored impacts of sequestration on Build America Bonds (BABs) and related issue of Clean Renewable Energy Bonds.
Expressed concerns about or opposition to markets issues related to regional transmission organizations, including proposed energy imbalance market and mandatory capacity markets; supported H.R. 624, CISPA (cyber information sharing); monitored development of executive order on cyber security and responded to NIST request for information; monitored issues related to electric vehicles, particularly regarding funding issues. Monitored development of revised Portman-Shaheen energy efficiency bill.Monitor rulemakings related to transmission policy. Worked to ensure small utilities that are defined as small businesses under SBREFA get appropriate consideration under any pending and future EPA and FERC regulations. Interfaced with DOE and DHS on recovery and resilience, as recommended by the National Infrastructure Advisory Committee (NIAC), and in handling Hurricane Sandy recovery. Supported Senator Klobuchar bill related to preventing copper theft. Asked FERC to grant rehearing of its definition of bulk electric system.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), Office of Management & Budget (OMB), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office
Support legislation to define parameters of EPA regulation of coal ash as a non-hazardous waste -- H.R. 1391, H.R. 2273 & S. 1751. Express concerns about regulation of cooling water intake structures (known as 316(b)) by EPA. Concern about air regulations on power plants being promulgated by EPA, including utility MACT (MATS), and support for the TRAIN Act to require multiple agencies to do cost-benefit analysis of EPA regs -- H.R. 2401. Monitoring possible revisions to EPA's final rule on reciprocating internal combustion engines (RICE) -- EPA-HQ-OAR-2008-0708. Monitoring EPA's proposed rule on New Source Performance Standard (NSPS) on greenhouse gas emissions on power plants. Continue to express concerns, particularly to FERC and EPA, about fuel switching from coal to natural gas and the operational implications therein.
Expressing concerns about or opposition to markets issues related to regional transmission organizations, including propose western energy imbalance market; opposed cyber security legislation involving the electric utility sector in the Senate -- revised version of S. 3414, and monitored development of executive order on cybe security; supported H.R. 4273 regarding emergency operation of power plants and Clean Air Act violations. Monitored issues related to electric vehicles, particularly regarding funding issues. Monitor rulemakings related to transmission policy, including transmission incentive rates. Worked to ensure small utilities that are defined as small businesses under SBREFA, get appropriate consideration under any pending and future EPA and FERC regulations. Interfaced with DOE and DHS on recovery and resilience, as recommended by the National Infrastructure Advisory Committee (NIAC), and in handling Hurricane Sandy recovery. Monitored Senator Klobuchar draft bill related to preventing copper theft.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), Office of Management & Budget (OMB), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office
Monitor smart grid programs and their intersection with the telecommunications industry, and respond to requests for meetings and information on the subject to DOE. Support for the need to allow electric utilities to access spectrum for wireless; monitoring implementation of S. 911 at NTIA.
Support the continued use of tax-exempt financing for municipal/public power purposes, and oppose provisions, like those included in the Administration's FY 2013 budget proposal and S. 727, to tax municipal bonds. Monitor legislation on expiring energy tax provisions such as H.R. 8 and S. 3521.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), Office of Management & Budget (OMB), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office
Support legislation to define parameters of EPA regulation of coal ash as a non-hazardous waste -- H.R. 1391, H.R. 2273 & S. 1751. Express concerns about regulation of cooling water intake structures (known as 316(b)) by EPA. Concern about air regulations on power plants being promulgated by EPA, including utility MACT (MATS), and support for the TRAIN Act to require multiple agencies to do cost-benefit analysis of EPA regs -- H.R. 2401. Monitoring possible revisions to EPA's final rule on reciprocating internal combustion engines (RICE) -- EPA-HQ-OAR-2008-0708. Monitoring EPA's pending decision (occurred in April 2012) on New Source Performance Standard (NSPS) on greenhouse gas emissions on power plants. Continue to express concerns, particularly to FERC and EPA, about fuel switching from coal to natural gas and the operational implications therein.
Supporting technology research and development related to electricity infrastructure technologies, including smart grid; expressing concerns about electricity markets issues related to regional transmission organizations; monitoring cyber security legislation involving the electric utility sector, including S. 1342, as well as the House GRID Act from the previous Congress (now in draft form), the SHIELD Act from this Congress, H.R. 3523, and the draft Seante HSGAC/Commerce bill from this Congress. Monitor rulemakings, legislation, & hearings related to transmission policy, including transmission incentive rates. Monitor funding and other policy issues related to electric vehicles and their integration into the electric grid. Discussion with FEMA regarding mutual aid agreements and utility restoration after natural disasters. Support draft legislation to enable power plants to run in emergency situations without being penalized by EPA for environmental (emissions) violations (Olson-Terry bill, H.R. 4273). Work to ensure small utilities that are defined as small businesses under SBREFA, get appropriate consideration under any pending and future EPA and FERC regulations.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Natl Telecommunications & Information Administration (NTIA), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office
Support bill encouraging energy efficiency, S. 1000. Monitor the Hydropower Improvement Act in the Senate, and support bills to ensure regulatory relief for small hydro facilities, such as H.R. 795, H.R. 2842 and H.R. 3680. Monitor activities of NRC on Yucca Mountain nuclear waste repository and congressional oversight thereof (support Yucca Mountain). Monitor NRC and congressional response to Fukushima event in Japan and implications for existing and new nuclear power generation. Monitor issues related to the export of liquefied natural gas (LNG).
Support the continued use of tax-exempt financing for municipal/public power purposes, and oppose provisions, like those included in the Administration's FY 2013 budget proposal, to tax municipal bonds. Support Clean Renewable Energy Bonds, the comparable incentive to the production tax credit for public power development of renewable resources.
Support legislation to define parameters of EPA regulation of coal ash as a non-hazardous waste -- H.R. 1391 and H.R. 2273. Express concerns about regulation of cooling water intake structures (known as 316(b)) by EPA. Concern about air regulations on power plants being promulgated by EPA, including utility MACT (MATS), and support for the TRAIN Act to require multiple agencies to do cost-benefit analysis of EPA regs -- H.R. 2401. Monitoring possible revisions to EPA's final rule on reciprocating internal combustion engines (RICE). Monitoring EPA's pending decision (occurred in April 2012) on New Source Performance Standard (NSPS) on greenhouse gas emissions on power plants. Continue to express concerns, particularly to FERC and EPA, about fuel switching from coal to natural gas and the operational implications therein.
Opposition to utility pole attachment regulations promulgated by the Federal Communications Commission. Monitor smart grid programs and their intersection with the telecommunications industry, and respond to requests for meetings and information on the subject to DOE. Monitor privacy-related bill involving data collection through smart grid, S. 1029 -- have concerns about bill as drafted. Support for the need to allow electric utilities to access spectrum for wireless; monitoring -- S. 911, and H.R. 3630.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office
Support the continued use of tax-exempt financing for municipal/public power purposes, and oppose provisions, like those included in the Administration's JOBS bill, to tax municipal bonds. Support Clean Renewable Energy Bonds, the comparable incentive to the production tax credit for public power development of renewable resources.
Support bill encouraging energy efficiency, S. 1000. Monitoring the Hydropower Improvement Act in the Senate, and support bills to ensure regulatory relief for small hydro facilities, H.R. 795 and H.R. 2842. Monitoring activities of NRC on Yucca Mountain nuclear waste repository and congressional oversight thereof (support Yucca Mountain). Monitoring NRC and congressional response to Fukushima event in Japan and implications for existing and new nuclear power generation. Monitoring issues related to the export of liquefied natural gas (LNG).
Supporting technology research and development related to electricity infrastructure technologies, including smart grid; expressing concerns about electricity markets issues related to regional transmission organizations; monitoring cyber security legislation involving the electric utility sector, including S. 1342, as well as the House GRID Act from the previous Congress (now in draft form), the SHIELD Act from this Congress, and the House Intelligence Committee cyber bill from this Congress. Monitoring rulemakings, legislation, & hearings related to transmission policy, including transmission incentive rates. Monitor funding and other policy issues related to electric vehicles and their integration into the electric grid. Discussion with FEMA regarding mutual aid agreements and utility restoration after natural disasters.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office
Support the continued use of tax-exempt financing for municipal/public power purposes, and oppose provisions, like those included in the Administration's JOBS bill, to tax municipal bonds. Support Clean Renewable Energy Bonds, the comparable incentive to the production tax credit for public power development of renewable resources.
Support bill encouraging energy efficiency, S. 1000. Monitoring the Hydropower Improvement Act in the Senate, and support bills to ensure regulatory relief for small hydro facilities, H.R. 795 and H.R. 2842. Monitoring activities of NRC on Yucca Mountain nuclear waste repository and congressional oversight thereof (support Yucca Mountain). Monitoring NRC and congressional response to Fukushima event in Japan and implications for existing and new nuclear power generation. Monitoring issues related to the export of liquefied natural gas (LNG).
Opposition to utility pole attachment regulations promulgated by the Federal Communications Commission. Monitoring smart grid programs and their intersection with the telecommunications industry, and responding to requests for meetings and information on the subject to DOE. Monitoring privacy-related bill involving data collection through smart grid, S. 1029 -- have concerns about bill as drafted. Support for the need to allow electric utilities to access spectrum for wireless; monitoring S. 911.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office
Opposition to utility pole attachment regulations promulgated by the Federal Communications Commission. Monitoring smart grid programs and their intersection with the telecommunications industry, and responding to requests for meetings and information on the subject to DOE. Monitoring privacy-related bill involving data collection through smart grid, S. 1029 -- have concerns about bill as drafted. Support for the need to allow electric utilities to access spectrum for wireless; monitoring S. 911.
Support bill encouraging energy efficiency, S. 1000. Monitoring the Hydropower Improvement Act in the Senate, and support bills to ensure regulatory relief for small hydro facilities, H.R. 795 and H.R. 2842. Monitoring activities of NRC on Yucca Mountain nuclear waste repository and congressional oversight thereof (support Yucca Mountain). Monitoring NRC and congressional response to Fukushima event in Japan and implications for existing and new nuclear power generation.
Support the continued use of tax-exempt financing for municipal/public power purposes, and oppose provisions, like those included in the Administration's JOBS bill, to tax municipal bonds.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office
Supporting technology research and development related to electricity infrastructure technologies, including smart grid; expressing concerns about electricity markets issues related to regional transmission organizations; monitoring cyber security legislation involving the electric utility sector, including S. 1342, as well as the House GRID Act from the previous Congress (now in draft form) and the SHIELD Act from this Congress. Monitoring rulemakings and legislation related to transmission policy.
Support for muncipal provision of broadband services; opposition to utility pole attachment regulations being proposed by the Federal Communications Commission. Monitoring smart grid programs and their intersection with the telecommunications industry, and responding to requests for meetings and information on the subject to DOE. Monitoring privacy-related issues involving data collection through the smart grid. Support for the need to allow electric utilities to access spectrum for wireless.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office
Support for muncipal provision of broadband services; opposition to utility pole attachment regulations being proposed by the Federal Communications Commission. Monitoring smart grid programs and their intersection with the telecommunications industry, and responding to requests for meetings and information on the subject to DOE. Monitoring privacy-related issues involving data collection through the smart grid and related legislation.
Supporting technology research and development related to electricity infrastructure technologies, including smart grid; expressing concerns about electricity markets issues related to regional transmission organizations, and seeking legislation to enhance data transparency in those markets; monitoring cyber security legislation involving the electric utility sector, including the cyber title of S. 1462 from the previous Congress as well as the GRID Act from the previous Congress and the SHIELD Act from this Congress.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office
Support for certain energy policy provisions included in S. 1462 from the last Congress, including plug-in hybrid electric vehicle programs, creation of the Clean Energy Development Administration, and energy efficiency programs. Monitoring the Hydropower Improvement Act. Monitoring and commenting on the idea of a Clean Energy Standard as proposed by President Obama.
Support for muncipal provision of broadband services; opposition to utility pole attachment regulations being proposed by the Federal Communications Commission. Monitoring smart grid programs and their intersection with the telecommunications industry, and responding to requests for meetings and information on the subject to DOE. Monitoring privacy-related issues involving data collection through the smart grid and related legislation.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office
Support for muncipal provision of broadband services; opposition to utility pole attachment regulations being proposed by the Federal Communications Commission. Monitoring smart grid programs and their intersection with the telecommunications industry, and responding to requests for meetings and information on the subject to DOE. Monitoring privacy-related issues involving data collection through the smart grid and related legislation.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office
Support for muncipal provision of broadband services; opposition to utility pole attachment regulations being proposed by the Federal Communications Commission. Monitoring smart grid programs and their intersection with the telecommunications industry, and responding to requests for meetings and information on the subject to DOE. Monitoring privacy-related issues involving data collection through the smart grid and related legislation.
Support technology research and development related to electricity infrastructure technologies, including smart grid, some positive provisions have been included in S. 1462; expressing concerns about electricity markets issues related to regional transmission organizations, and seeking legislation to enhance data transparency in those markets; monitoring cyber security legislation involving the electric utility sector, including the cyber title of S. 1462, as well as S. 3480 and S. 3538. Monitoring Hastings bill to reform the transmission infrastructre program of the Western Area Power Adminstration.
Filing targets: Agriculture, Dept of (USDA), Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office
-climate change -Clean Water Act issues -Clean Air Act issues
-Clean Renewable Energy Bonds -tax-credit bond issues generally -tax-exempt financing issues generally
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of