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.
Water Systems PFAS Liability Protection Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 3898, the PERMIT Act, to improve the permitting process for infrastructure projects under the Clean Water Act, the provision regarding nationwide permitting and the determination of the appropriate acreage threshold for discharges into WOTUS, and the provision regarding section 18 statutory exclusion from the regulatory definition of WOTUS for waste treatment systems. Discussed support for H.R. 161, the New Source Review Permitting Improvement Act (all provisions). Discussed H.R. 1267, the PFAS Water Systems Liability Act, regarding how utilities are passive receivers of PFAS. Discussed the technology-based effluent limitations and standards for the Steam Electric Power Generating Point Source that the Environmental Protection Agency (EPA) promulgated in 2024 (RIN: 2040-AG41). Discussed EPAs proposed rule to approve state implementation plans for the 2015 ozone ambient air quality standards based on the agencys conclusion that 10 states dont contribute to downwind state nonattainment (EPA-HQ-OAR-2025-0192).
Water Systems PFAS Liability Protection Act
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
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.
New Source Review Permitting Improvement Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 3898, the PERMIT Act, to improve the permitting process for infrastructure projects under the Clean Water Act, the provision regarding nationwide permitting and the determination of the appropriate acreage threshold for discharges into WOTUS, and the provision regarding section 18 statutory exclusion from the regulatory definition of WOTUS for waste treatment systems. Discussed support for H.R. 161, the New Source Review Permitting Improvement Act (all provisions). Discussed H.R. 9855, the Certainty and Uniform Reviews for Reliable Energy and Transmission (CERTAIN) Act, to amend the Federal Water Pollution Control Act to make certain reforms with respect to permits and licenses under such act. Specifically discussed amending the Clean Water Act section 401 water quality certification process. Discussed support for H.R. 9855, the CERTAIN Act.
New Source Review Permitting Improvement Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 3898, the PERMIT Act, to improve the permitting process for infrastructure projects under the Clean Water Act, the provision regarding nationwide permitting and the determination of the appropriate acreage threshold for discharges into WOTUS, and the provision regarding section 18 statutory exclusion from the regulatory definition of WOTUS for waste treatment systems. Discussed support for H.R. 161, the New Source Review Permitting Improvement Act (all provisions). Discussed H.R. 1267, the PFAS Water Systems Liability Act, regarding how utilities are passive receivers of PFAS. Discussed the technology-based effluent limitations and standards for the Steam Electric Power Generating Point Source that the Environmental Protection Agency (EPA) promulgated in 2024 (RIN: 2040-AG41). Discussed EPAs proposed rule to approve state implementation plans for the 2015 ozone ambient air quality standards based on the agencys conclusion that 10 states dont contribute to downwind state nonattainment (EPA-HQ-OAR-2025-0192).
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.
ESA Amendments Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 4776, the SPEED Act, to reform permitting processes under the National Environmental Policy Act (all provisions). Discussed support for H.R. 4503, the ePermit Act, to digitize the federal permitting process for environmental reviews. Discussed support of reforms to the Endangered Species Act that would change the definition of habitat (no legislation). Discussed how the Endangered Species Act impacts energy infrastructure projects (no legislation). Discussed H.R. 1897, the Endangered Species Act Amendments of 2025 (all provisions). Discussed the Environmental Protection Agencys reconsideration of the 2024 Coal Combustion Residuals Legacy rule regarding the disposal of coal combustion residuals and impoundments (RIN: 2050-AH39).
To require the Federal Energy Regulatory Commission to extend the time period during which licensees are required to commence construction of certain hydropower projects.
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the Cybersecurity and Information Security Agencys (CISA) work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for S. 2983, the Protecting America from Cyber Threats Act (all provisions), to reauthorize the Cybersecurity Information Security Act of 2015 (CISA 2015). Discussed support for a replacement to the Critical Infrastructure Partnership Advisory Council at the Department of Homeland Security to facilitate interaction between governmental entities and representatives from the community of critical infrastructure owners and operators. (no legislation). Discussed support for H.R. 7258, the Energy Emergency Leadership Act, to elevate the Department of Energys energy emergency and cybersecurity responsibilities by requiring those critical functions to be led by a Senate-confirmed Assistant Secretary (all provisions). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 2072, the Build More Hydro Act, to require the Federal Energy Regulatory Commission to extend the period during which licensees are required to commence construction of certain hydropower projects (all provisions). Discussed H.R. 7940, the Safeguarding Aquatic Fisheries and Ecosystem (SAFE) Pathways Act, to amend the Federal Power Act to require the consideration of invasive species when prescribing fishways. Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed the role of grid enhancing technologies in transmission and virtual power plants (no legislation). Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed H.R. 7977, the transmission provisions in the Energy Bills Relief Act. Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 3947, the REWIRE Act, section 3, to provide categorical exclusions for transmission projects that increase grid capacity in existing rights-of-way by reconductoring, using grid enhancing technologies, and deploying energy storage, and section 4, to increase return on equity for reconductoring using advanced conductors. Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Discussed H.R. 7329, the Fighting for Reliable Energy and Ending Doubt for Open Markets (FREEDOM) Act, to amend the Energy Act of 2020, the Geothermal Steam Act of 1970, the Energy Policy Act of 2005, and the Mineral Leasing Act to streamline the leasing and permitting processes of federal agencies for certain energy and mineral projects, to clarify federal authorization requirements for certain projects on non-federal land, to establish enforceable federal authorization timelines and expedited judicial remedies, to limit federal actions halting fully permitted projects, to create a de-risking compensation program. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed draft legislation, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed Light Up Navajo project to get electricity to unserved families of the Navajo Nation (no legislation). Discussed ongoing grid hardening activities by public power utilities and needed additional investments (no legislation). Discussed potential federal funding for critical infrastructure hardening. Discussed the impact tariffs are having on public power utilities (no legislation). Discussed the impact of supply chain issues on public power utilities (no legislation). Discussed the impact from data centers on electricity prices to customers in communities that dont have data centers (FERC Docket RM26-4). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives. Discussed wholesale electricity market development efforts in the West. Discussed the public power business model and FERCs jurisdiction over public power utilities under the Federal Power Act.
Maintaining and Enhancing Hydroelectricity and River Restoration Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed 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.
Southwestern Power Administration Fund Establishment Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed the need for action on categorical exclusions for vegetation management along power line corridors. Also discussed strict liability for utilities operating on public lands for wildfires. Discussed the importance of the federal Power Marketing Administrations that provide federal hydropower to public power utilities and opposition to any attempts to privatize them in whole or in part. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions). Discussed support for the acting commissioner of the Bureau of Reclamation to release funds in the Colorado River Dam Fund for the acquisition of wide head turbines at Hoover Dam as directed to in the report language accompanying H.R. 6938, the Energy & Water Development Appropriations Act, 2026. Discussed the need to exempt the Boulder Canyon Dam Project from the Federal Lands Recreation Enhancement Act (P.L. 108‑447), which would give the Bureau of Reclamation the ability to collect entry fees at Hoover Dam (no legislation).
Reliable Power Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the Cybersecurity and Information Security Agencys (CISA) work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for S. 2983, the Protecting America from Cyber Threats Act (all provisions), to reauthorize the Cybersecurity Information Security Act of 2015 (CISA 2015). Discussed support for a replacement to the Critical Infrastructure Partnership Advisory Council at the Department of Homeland Security to facilitate interaction between governmental entities and representatives from the community of critical infrastructure owners and operators. (no legislation). Discussed support for H.R. 7258, the Energy Emergency Leadership Act, to elevate the Department of Energys energy emergency and cybersecurity responsibilities by requiring those critical functions to be led by a Senate-confirmed Assistant Secretary (all provisions). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 2072, the Build More Hydro Act, to require the Federal Energy Regulatory Commission to extend the period during which licensees are required to commence construction of certain hydropower projects (all provisions). Discussed H.R. 7940, the Safeguarding Aquatic Fisheries and Ecosystem (SAFE) Pathways Act, to amend the Federal Power Act to require the consideration of invasive species when prescribing fishways. Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed the role of grid enhancing technologies in transmission and virtual power plants (no legislation). Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed H.R. 7977, the transmission provisions in the Energy Bills Relief Act. Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 3947, the REWIRE Act, section 3, to provide categorical exclusions for transmission projects that increase grid capacity in existing rights-of-way by reconductoring, using grid enhancing technologies, and deploying energy storage, and section 4, to increase return on equity for reconductoring using advanced conductors. Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Discussed H.R. 7329, the Fighting for Reliable Energy and Ending Doubt for Open Markets (FREEDOM) Act, to amend the Energy Act of 2020, the Geothermal Steam Act of 1970, the Energy Policy Act of 2005, and the Mineral Leasing Act to streamline the leasing and permitting processes of federal agencies for certain energy and mineral projects, to clarify federal authorization requirements for certain projects on non-federal land, to establish enforceable federal authorization timelines and expedited judicial remedies, to limit federal actions halting fully permitted projects, to create a de-risking compensation program. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed draft legislation, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed Light Up Navajo project to get electricity to unserved families of the Navajo Nation (no legislation). Discussed ongoing grid hardening activities by public power utilities and needed additional investments (no legislation). Discussed potential federal funding for critical infrastructure hardening. Discussed the impact tariffs are having on public power utilities (no legislation). Discussed the impact of supply chain issues on public power utilities (no legislation). Discussed the impact from data centers on electricity prices to customers in communities that dont have data centers (FERC Docket RM26-4). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives. Discussed wholesale electricity market development efforts in the West. Discussed the public power business model and FERCs jurisdiction over public power utilities under the Federal Power Act.
PERMIT Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 3898, the PERMIT Act, to improve the permitting process for infrastructure projects under the Clean Water Act, the provision regarding nationwide permitting and the determination of the appropriate acreage threshold for discharges into WOTUS, and the provision regarding section 18 statutory exclusion from the regulatory definition of WOTUS for waste treatment systems. Discussed support for H.R. 161, the New Source Review Permitting Improvement Act (all provisions). Discussed H.R. 9855, the Certainty and Uniform Reviews for Reliable Energy and Transmission (CERTAIN) Act, to amend the Federal Water Pollution Control Act to make certain reforms with respect to permits and licenses under such act. Specifically discussed amending the Clean Water Act section 401 water quality certification process. Discussed support for H.R. 9855, the CERTAIN Act.
PERMIT Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 3898, the PERMIT Act, to improve the permitting process for infrastructure projects under the Clean Water Act, the provision regarding nationwide permitting and the determination of the appropriate acreage threshold for discharges into WOTUS, and the provision regarding section 18 statutory exclusion from the regulatory definition of WOTUS for waste treatment systems. Discussed support for H.R. 161, the New Source Review Permitting Improvement Act (all provisions). Discussed H.R. 1267, the PFAS Water Systems Liability Act, regarding how utilities are passive receivers of PFAS. Discussed the technology-based effluent limitations and standards for the Steam Electric Power Generating Point Source that the Environmental Protection Agency (EPA) promulgated in 2024 (RIN: 2040-AG41). Discussed EPAs proposed rule to approve state implementation plans for the 2015 ozone ambient air quality standards based on the agencys conclusion that 10 states dont contribute to downwind state nonattainment (EPA-HQ-OAR-2025-0192).
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.
ePermit Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 4776, the SPEED Act, to reform permitting processes under the National Environmental Policy Act (all provisions). Discussed support for H.R. 4503, the ePermit Act, to digitize the federal permitting process for environmental reviews. Discussed support of reforms to the Endangered Species Act that would change the definition of habitat (no legislation). Discussed how the Endangered Species Act impacts energy infrastructure projects (no legislation). Discussed H.R. 1897, the Endangered Species Act Amendments of 2025 (all provisions). Discussed the Environmental Protection Agencys reconsideration of the 2024 Coal Combustion Residuals Legacy rule regarding the disposal of coal combustion residuals and impoundments (RIN: 2050-AH39).
Fix Our Forests Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed support for agency actions to expedite environmental reviews under the National Environmental Policy Act, Endangered Species Act, and National Historic Preservation Act to reduce the risk of wildfires. Discussed strict liability caps for wildfires on federal lands under the Forest Land Policy and Management Act (P.L. 94-579). Discussed the need for more consistency of land management practices at federal land management agencies, such as U.S. Forest Service and the Bureau of Land Management. Discussed support for comprehensive vegetation management practices along power line corridors on federal lands. Discussed Bonneville Power Administrations role in transmission in the Pacific Northwest (no legislation). Discussed the federal hydropower system in the Pacific Northwest (no legislation). Discussed support for adequate staffing levels at the federal Power Marketing Administrations (no legislation).
Fix Our Forests Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed the need for action on categorical exclusions for vegetation management along power line corridors. Also discussed strict liability for utilities operating on public lands for wildfires. Discussed the importance of the federal Power Marketing Administrations that provide federal hydropower to public power utilities and opposition to any attempts to privatize them in whole or in part. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions). Discussed support for the acting commissioner of the Bureau of Reclamation to release funds in the Colorado River Dam Fund for the acquisition of wide head turbines at Hoover Dam as directed to in the report language accompanying H.R. 6938, the Energy & Water Development Appropriations Act, 2026. Discussed the need to exempt the Boulder Canyon Dam Project from the Federal Lands Recreation Enhancement Act (P.L. 108‑447), which would give the Bureau of Reclamation the ability to collect entry fees at Hoover Dam (no legislation).
SPEED Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 4776, the SPEED Act, to reform permitting processes under the National Environmental Policy Act (all provisions). Discussed support for H.R. 4503, the ePermit Act, to digitize the federal permitting process for environmental reviews. Discussed support 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.
SPEED Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 4776, the SPEED Act, to reform permitting processes under the National Environmental Policy Act (all provisions). Discussed support for H.R. 4503, the ePermit Act, to digitize the federal permitting process for environmental reviews. Discussed support of reforms to the Endangered Species Act that would change the definition of habitat (no legislation). Discussed how the Endangered Species Act impacts energy infrastructure projects (no legislation). Discussed H.R. 1897, the Endangered Species Act Amendments of 2025 (all provisions). Discussed the Environmental Protection Agencys reconsideration of the 2024 Coal Combustion Residuals Legacy rule regarding the disposal of coal combustion residuals and impoundments (RIN: 2050-AH39).
Commerce, Justice, Science; Energy and Water Development; and Interior and Environment Appropriations Act, 2026
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed the need for action on categorical exclusions for vegetation management along power line corridors. Also discussed strict liability for utilities operating on public lands for wildfires. Discussed the importance of the federal Power Marketing Administrations that provide federal hydropower to public power utilities and opposition to any attempts to privatize them in whole or in part. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions). Discussed support for the acting commissioner of the Bureau of Reclamation to release funds in the Colorado River Dam Fund for the acquisition of wide head turbines at Hoover Dam as directed to in the report language accompanying H.R. 6938, the Energy & Water Development Appropriations Act, 2026. Discussed the need to exempt the Boulder Canyon Dam Project from the Federal Lands Recreation Enhancement Act (P.L. 108‑447), which would give the Bureau of Reclamation the ability to collect entry fees at Hoover Dam (no legislation).
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 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 the Cybersecurity and Information Security Agencys (CISA) work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for S. 2983, the Protecting America from Cyber Threats Act (all provisions), to reauthorize the Cybersecurity Information Security Act of 2015 (CISA 2015). Discussed support for a replacement to the Critical Infrastructure Partnership Advisory Council at the Department of Homeland Security to facilitate interaction between governmental entities and representatives from the community of critical infrastructure owners and operators. (no legislation). Discussed support for H.R. 7258, the Energy Emergency Leadership Act, to elevate the Department of Energys energy emergency and cybersecurity responsibilities by requiring those critical functions to be led by a Senate-confirmed Assistant Secretary (all provisions). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 2072, the Build More Hydro Act, to require the Federal Energy Regulatory Commission to extend the period during which licensees are required to commence construction of certain hydropower projects (all provisions). Discussed H.R. 7940, the Safeguarding Aquatic Fisheries and Ecosystem (SAFE) Pathways Act, to amend the Federal Power Act to require the consideration of invasive species when prescribing fishways. Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed the role of grid enhancing technologies in transmission and virtual power plants (no legislation). Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed H.R. 7977, the transmission provisions in the Energy Bills Relief Act. Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 3947, the REWIRE Act, section 3, to provide categorical exclusions for transmission projects that increase grid capacity in existing rights-of-way by reconductoring, using grid enhancing technologies, and deploying energy storage, and section 4, to increase return on equity for reconductoring using advanced conductors. Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Discussed H.R. 7329, the Fighting for Reliable Energy and Ending Doubt for Open Markets (FREEDOM) Act, to amend the Energy Act of 2020, the Geothermal Steam Act of 1970, the Energy Policy Act of 2005, and the Mineral Leasing Act to streamline the leasing and permitting processes of federal agencies for certain energy and mineral projects, to clarify federal authorization requirements for certain projects on non-federal land, to establish enforceable federal authorization timelines and expedited judicial remedies, to limit federal actions halting fully permitted projects, to create a de-risking compensation program. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed draft legislation, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed Light Up Navajo project to get electricity to unserved families of the Navajo Nation (no legislation). Discussed ongoing grid hardening activities by public power utilities and needed additional investments (no legislation). Discussed potential federal funding for critical infrastructure hardening. Discussed the impact tariffs are having on public power utilities (no legislation). Discussed the impact of supply chain issues on public power utilities (no legislation). Discussed the impact from data centers on electricity prices to customers in communities that dont have data centers (FERC Docket RM26-4). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives. Discussed wholesale electricity market development efforts in the West. Discussed the public power business model and FERCs jurisdiction over public power utilities under the Federal Power Act.
AI Fraud Accountability Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 9337, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed H.R. 6633, the High-Capacity Grid Act (all provisions), to establish a best-available transmission conductor standard for certain transmission projects under the Federal Power Act and to provide for presumptions regarding cost recovery for such conductors. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give the Federal Energy Regulatory Commission the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 9332, the Load Forecasting Enhancement Act, to require the Federal Energy Regulatory Commission to establish regional joint boards to study electric load forecasting. Discussed technical assistance for public power utilities for load forecasting. Discussed H.R. 9340, the Ratepayer Protection Act, to amend the Public Utility Regulatory Policies Act of 1978 to establish a federal standard relating to the recovery of the full, incremental costs of upgrades that serve large-load customers (all provisions). Discussed Winter Storm Fern and the use of section 202(c) orders by the Department of Energy to ensure grid reliability. Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Provided feedback on draft legislation, the State Energy Oversight Act, on performance-based ratemaking. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed support for H.R. 8308, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed the importance of coordination between the military and public power utilities that serve them (no legislation). Discussed issues related to defense critical electric infrastructure, including the importance of coordination between the military and Department of Energy (no legislation). Discussed existing cooperative agreements with the Department of Energy (DE-CR0000007, DE-CR0000015, and DE-CR0000026. Discussed the Executive Order on Artificial Intelligence. Discussion of distribution transformer supply chain challenges (no legislation). Discussed the impact of federal trade policies on supply chains for public power utilities (no legislation). Discussed supply chain issues facing public power utilities and the significant cost increases they are seeing for key electrical equipment that can only be acquired abroad (no legislation). Discussed the importance of the Tennessee Valley Authority to public power utilities served by it. Discussed the public power business model (no legislation). Discussed energy affordability and all the actions public power utilities take to keep electricity affordable for their customers and to assist those in need (no legislation). Discussed how public power utilities are working to ensure their customers do not bear the costs of serving large computational loads (no legislation). Discussed issues related to data center affordability and support for efforts to protect affordability and reliability, as well as ensuring a voice for public power in evaluating governance issues (FERC Docket RM26-4 and AD26-7). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives.
SAFE Pathways Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the Cybersecurity and Information Security Agencys (CISA) work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for S. 2983, the Protecting America from Cyber Threats Act (all provisions), to reauthorize the Cybersecurity Information Security Act of 2015 (CISA 2015). Discussed support for a replacement to the Critical Infrastructure Partnership Advisory Council at the Department of Homeland Security to facilitate interaction between governmental entities and representatives from the community of critical infrastructure owners and operators. (no legislation). Discussed support for H.R. 7258, the Energy Emergency Leadership Act, to elevate the Department of Energys energy emergency and cybersecurity responsibilities by requiring those critical functions to be led by a Senate-confirmed Assistant Secretary (all provisions). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 2072, the Build More Hydro Act, to require the Federal Energy Regulatory Commission to extend the period during which licensees are required to commence construction of certain hydropower projects (all provisions). Discussed H.R. 7940, the Safeguarding Aquatic Fisheries and Ecosystem (SAFE) Pathways Act, to amend the Federal Power Act to require the consideration of invasive species when prescribing fishways. Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed the role of grid enhancing technologies in transmission and virtual power plants (no legislation). Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed H.R. 7977, the transmission provisions in the Energy Bills Relief Act. Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 3947, the REWIRE Act, section 3, to provide categorical exclusions for transmission projects that increase grid capacity in existing rights-of-way by reconductoring, using grid enhancing technologies, and deploying energy storage, and section 4, to increase return on equity for reconductoring using advanced conductors. Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Discussed H.R. 7329, the Fighting for Reliable Energy and Ending Doubt for Open Markets (FREEDOM) Act, to amend the Energy Act of 2020, the Geothermal Steam Act of 1970, the Energy Policy Act of 2005, and the Mineral Leasing Act to streamline the leasing and permitting processes of federal agencies for certain energy and mineral projects, to clarify federal authorization requirements for certain projects on non-federal land, to establish enforceable federal authorization timelines and expedited judicial remedies, to limit federal actions halting fully permitted projects, to create a de-risking compensation program. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed draft legislation, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed Light Up Navajo project to get electricity to unserved families of the Navajo Nation (no legislation). Discussed ongoing grid hardening activities by public power utilities and needed additional investments (no legislation). Discussed potential federal funding for critical infrastructure hardening. Discussed the impact tariffs are having on public power utilities (no legislation). Discussed the impact of supply chain issues on public power utilities (no legislation). Discussed the impact from data centers on electricity prices to customers in communities that dont have data centers (FERC Docket RM26-4). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives. Discussed wholesale electricity market development efforts in the West. Discussed the public power business model and FERCs jurisdiction over public power utilities under the Federal Power Act.
Energy Bills Relief Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the Cybersecurity and Information Security Agencys (CISA) work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for S. 2983, the Protecting America from Cyber Threats Act (all provisions), to reauthorize the Cybersecurity Information Security Act of 2015 (CISA 2015). Discussed support for a replacement to the Critical Infrastructure Partnership Advisory Council at the Department of Homeland Security to facilitate interaction between governmental entities and representatives from the community of critical infrastructure owners and operators. (no legislation). Discussed support for H.R. 7258, the Energy Emergency Leadership Act, to elevate the Department of Energys energy emergency and cybersecurity responsibilities by requiring those critical functions to be led by a Senate-confirmed Assistant Secretary (all provisions). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 2072, the Build More Hydro Act, to require the Federal Energy Regulatory Commission to extend the period during which licensees are required to commence construction of certain hydropower projects (all provisions). Discussed H.R. 7940, the Safeguarding Aquatic Fisheries and Ecosystem (SAFE) Pathways Act, to amend the Federal Power Act to require the consideration of invasive species when prescribing fishways. Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed the role of grid enhancing technologies in transmission and virtual power plants (no legislation). Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed H.R. 7977, the transmission provisions in the Energy Bills Relief Act. Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 3947, the REWIRE Act, section 3, to provide categorical exclusions for transmission projects that increase grid capacity in existing rights-of-way by reconductoring, using grid enhancing technologies, and deploying energy storage, and section 4, to increase return on equity for reconductoring using advanced conductors. Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Discussed H.R. 7329, the Fighting for Reliable Energy and Ending Doubt for Open Markets (FREEDOM) Act, to amend the Energy Act of 2020, the Geothermal Steam Act of 1970, the Energy Policy Act of 2005, and the Mineral Leasing Act to streamline the leasing and permitting processes of federal agencies for certain energy and mineral projects, to clarify federal authorization requirements for certain projects on non-federal land, to establish enforceable federal authorization timelines and expedited judicial remedies, to limit federal actions halting fully permitted projects, to create a de-risking compensation program. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed draft legislation, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed Light Up Navajo project to get electricity to unserved families of the Navajo Nation (no legislation). Discussed ongoing grid hardening activities by public power utilities and needed additional investments (no legislation). Discussed potential federal funding for critical infrastructure hardening. Discussed the impact tariffs are having on public power utilities (no legislation). Discussed the impact of supply chain issues on public power utilities (no legislation). Discussed the impact from data centers on electricity prices to customers in communities that dont have data centers (FERC Docket RM26-4). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives. Discussed wholesale electricity market development efforts in the West. Discussed the public power business model and FERCs jurisdiction over public power utilities under the Federal Power Act.
Hydropower Licensing Affordability Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 7266/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.
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.
Water Resources Development Act of 2026
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the need for the U.S. Forest Service and Department of Interior to use existing authorities under section 512 of the Federal Land Policy and Management Act to allow electric utilities to better implement wildfire risk reduction. Discussed support for changes in the managers amendment to H.R. 9497, the Water Resources Development Act of 2026, to clarify that a new Office of Water Supply at the Army Corps of Engineers responsibilities are carried out in a manner that is consistent with authorized hydropower purposes at Corps projects (section 101). Discussed H.R. 9637, the Protecting Columbia River Salmon Act of 2026 to protect salmon from sea lion predation (all provisions).
Protecting Columbia River Salmon Act of 2026
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the need for the U.S. Forest Service and Department of Interior to use existing authorities under section 512 of the Federal Land Policy and Management Act to allow electric utilities to better implement wildfire risk reduction. Discussed support for changes in the managers amendment to H.R. 9497, the Water Resources Development Act of 2026, to clarify that a new Office of Water Supply at the Army Corps of Engineers responsibilities are carried out in a manner that is consistent with authorized hydropower purposes at Corps projects (section 101). Discussed H.R. 9637, the Protecting Columbia River Salmon Act of 2026 to protect salmon from sea lion predation (all provisions).
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.
CURRENT Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 3898, the PERMIT Act, to improve the permitting process for infrastructure projects under the Clean Water Act, the provision regarding nationwide permitting and the determination of the appropriate acreage threshold for discharges into WOTUS, and the provision regarding section 18 statutory exclusion from the regulatory definition of WOTUS for waste treatment systems. Discussed support for H.R. 161, the New Source Review Permitting Improvement Act (all provisions). Discussed H.R. 9855, the Certainty and Uniform Reviews for Reliable Energy and Transmission (CERTAIN) Act, to amend the Federal Water Pollution Control Act to make certain reforms with respect to permits and licenses under such act. Specifically discussed amending the Clean Water Act section 401 water quality certification process. Discussed support for H.R. 9855, the CERTAIN Act.
Southwestern Power Administration Fund Establishment Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed the need for action on categorical exclusions for vegetation management along power line corridors. Also discussed strict liability for utilities operating on public lands for wildfires. Discussed the importance of the federal Power Marketing Administrations that provide federal hydropower to public power utilities and opposition to any attempts to privatize them in whole or in part. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions). Discussed support for the acting commissioner of the Bureau of Reclamation to release funds in the Colorado River Dam Fund for the acquisition of wide head turbines at Hoover Dam as directed to in the report language accompanying H.R. 6938, the Energy & Water Development Appropriations Act, 2026. Discussed the need to exempt the Boulder Canyon Dam Project from the Federal Lands Recreation Enhancement Act (P.L. 108‑447), which would give the Bureau of Reclamation the ability to collect entry fees at Hoover Dam (no legislation).
Maintaining and Enhancing Hydroelectricity and River Restoration Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the Cybersecurity and Information Security Agencys (CISA) work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for S. 2983, the Protecting America from Cyber Threats Act (all provisions), to reauthorize the Cybersecurity Information Security Act of 2015 (CISA 2015). Discussed support for a replacement to the Critical Infrastructure Partnership Advisory Council at the Department of Homeland Security to facilitate interaction between governmental entities and representatives from the community of critical infrastructure owners and operators. (no legislation). Discussed support for H.R. 7258, the Energy Emergency Leadership Act, to elevate the Department of Energys energy emergency and cybersecurity responsibilities by requiring those critical functions to be led by a Senate-confirmed Assistant Secretary (all provisions). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 2072, the Build More Hydro Act, to require the Federal Energy Regulatory Commission to extend the period during which licensees are required to commence construction of certain hydropower projects (all provisions). Discussed H.R. 7940, the Safeguarding Aquatic Fisheries and Ecosystem (SAFE) Pathways Act, to amend the Federal Power Act to require the consideration of invasive species when prescribing fishways. Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed the role of grid enhancing technologies in transmission and virtual power plants (no legislation). Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed H.R. 7977, the transmission provisions in the Energy Bills Relief Act. Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 3947, the REWIRE Act, section 3, to provide categorical exclusions for transmission projects that increase grid capacity in existing rights-of-way by reconductoring, using grid enhancing technologies, and deploying energy storage, and section 4, to increase return on equity for reconductoring using advanced conductors. Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Discussed H.R. 7329, the Fighting for Reliable Energy and Ending Doubt for Open Markets (FREEDOM) Act, to amend the Energy Act of 2020, the Geothermal Steam Act of 1970, the Energy Policy Act of 2005, and the Mineral Leasing Act to streamline the leasing and permitting processes of federal agencies for certain energy and mineral projects, to clarify federal authorization requirements for certain projects on non-federal land, to establish enforceable federal authorization timelines and expedited judicial remedies, to limit federal actions halting fully permitted projects, to create a de-risking compensation program. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed draft legislation, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed Light Up Navajo project to get electricity to unserved families of the Navajo Nation (no legislation). Discussed ongoing grid hardening activities by public power utilities and needed additional investments (no legislation). Discussed potential federal funding for critical infrastructure hardening. Discussed the impact tariffs are having on public power utilities (no legislation). Discussed the impact of supply chain issues on public power utilities (no legislation). Discussed the impact from data centers on electricity prices to customers in communities that dont have data centers (FERC Docket RM26-4). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives. Discussed wholesale electricity market development efforts in the West. Discussed the public power business model and FERCs jurisdiction over public power utilities under the Federal Power Act.
Fix Our Forests Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed support for agency actions to expedite environmental reviews under the National Environmental Policy Act, Endangered Species Act, and National Historic Preservation Act to reduce the risk of wildfires. Discussed strict liability caps for wildfires on federal lands under the Forest Land Policy and Management Act (P.L. 94-579). Discussed the need for more consistency of land management practices at federal land management agencies, such as U.S. Forest Service and the Bureau of Land Management. Discussed support for comprehensive vegetation management practices along power line corridors on federal lands. Discussed Bonneville Power Administrations role in transmission in the Pacific Northwest (no legislation). Discussed the federal hydropower system in the Pacific Northwest (no legislation). Discussed support for adequate staffing levels at the federal Power Marketing Administrations (no legislation).
Fix Our Forests Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed the need for action on categorical exclusions for vegetation management along power line corridors. Also discussed strict liability for utilities operating on public lands for wildfires. Discussed the importance of the federal Power Marketing Administrations that provide federal hydropower to public power utilities and opposition to any attempts to privatize them in whole or in part. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions). Discussed support for the acting commissioner of the Bureau of Reclamation to release funds in the Colorado River Dam Fund for the acquisition of wide head turbines at Hoover Dam as directed to in the report language accompanying H.R. 6938, the Energy & Water Development Appropriations Act, 2026. Discussed the need to exempt the Boulder Canyon Dam Project from the Federal Lands Recreation Enhancement Act (P.L. 108‑447), which would give the Bureau of Reclamation the ability to collect entry fees at Hoover Dam (no legislation).
Reliable Power Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the Cybersecurity and Information Security Agencys (CISA) work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for S. 2983, the Protecting America from Cyber Threats Act (all provisions), to reauthorize the Cybersecurity Information Security Act of 2015 (CISA 2015). Discussed support for a replacement to the Critical Infrastructure Partnership Advisory Council at the Department of Homeland Security to facilitate interaction between governmental entities and representatives from the community of critical infrastructure owners and operators. (no legislation). Discussed support for H.R. 7258, the Energy Emergency Leadership Act, to elevate the Department of Energys energy emergency and cybersecurity responsibilities by requiring those critical functions to be led by a Senate-confirmed Assistant Secretary (all provisions). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 2072, the Build More Hydro Act, to require the Federal Energy Regulatory Commission to extend the period during which licensees are required to commence construction of certain hydropower projects (all provisions). Discussed H.R. 7940, the Safeguarding Aquatic Fisheries and Ecosystem (SAFE) Pathways Act, to amend the Federal Power Act to require the consideration of invasive species when prescribing fishways. Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed the role of grid enhancing technologies in transmission and virtual power plants (no legislation). Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed H.R. 7977, the transmission provisions in the Energy Bills Relief Act. Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 3947, the REWIRE Act, section 3, to provide categorical exclusions for transmission projects that increase grid capacity in existing rights-of-way by reconductoring, using grid enhancing technologies, and deploying energy storage, and section 4, to increase return on equity for reconductoring using advanced conductors. Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Discussed H.R. 7329, the Fighting for Reliable Energy and Ending Doubt for Open Markets (FREEDOM) Act, to amend the Energy Act of 2020, the Geothermal Steam Act of 1970, the Energy Policy Act of 2005, and the Mineral Leasing Act to streamline the leasing and permitting processes of federal agencies for certain energy and mineral projects, to clarify federal authorization requirements for certain projects on non-federal land, to establish enforceable federal authorization timelines and expedited judicial remedies, to limit federal actions halting fully permitted projects, to create a de-risking compensation program. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed draft legislation, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed Light Up Navajo project to get electricity to unserved families of the Navajo Nation (no legislation). Discussed ongoing grid hardening activities by public power utilities and needed additional investments (no legislation). Discussed potential federal funding for critical infrastructure hardening. Discussed the impact tariffs are having on public power utilities (no legislation). Discussed the impact of supply chain issues on public power utilities (no legislation). Discussed the impact from data centers on electricity prices to customers in communities that dont have data centers (FERC Docket RM26-4). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives. Discussed wholesale electricity market development efforts in the West. Discussed the public power business model and FERCs jurisdiction over public power utilities under the Federal Power Act.
Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 9337, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed H.R. 6633, the High-Capacity Grid Act (all provisions), to establish a best-available transmission conductor standard for certain transmission projects under the Federal Power Act and to provide for presumptions regarding cost recovery for such conductors. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give the Federal Energy Regulatory Commission the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 9332, the Load Forecasting Enhancement Act, to require the Federal Energy Regulatory Commission to establish regional joint boards to study electric load forecasting. Discussed technical assistance for public power utilities for load forecasting. Discussed H.R. 9340, the Ratepayer Protection Act, to amend the Public Utility Regulatory Policies Act of 1978 to establish a federal standard relating to the recovery of the full, incremental costs of upgrades that serve large-load customers (all provisions). Discussed Winter Storm Fern and the use of section 202(c) orders by the Department of Energy to ensure grid reliability. Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Provided feedback on draft legislation, the State Energy Oversight Act, on performance-based ratemaking. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed support for H.R. 8308, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed the importance of coordination between the military and public power utilities that serve them (no legislation). Discussed issues related to defense critical electric infrastructure, including the importance of coordination between the military and Department of Energy (no legislation). Discussed existing cooperative agreements with the Department of Energy (DE-CR0000007, DE-CR0000015, and DE-CR0000026. Discussed the Executive Order on Artificial Intelligence. Discussion of distribution transformer supply chain challenges (no legislation). Discussed the impact of federal trade policies on supply chains for public power utilities (no legislation). Discussed supply chain issues facing public power utilities and the significant cost increases they are seeing for key electrical equipment that can only be acquired abroad (no legislation). Discussed the importance of the Tennessee Valley Authority to public power utilities served by it. Discussed the public power business model (no legislation). Discussed energy affordability and all the actions public power utilities take to keep electricity affordable for their customers and to assist those in need (no legislation). Discussed how public power utilities are working to ensure their customers do not bear the costs of serving large computational loads (no legislation). Discussed issues related to data center affordability and support for efforts to protect affordability and reliability, as well as ensuring a voice for public power in evaluating governance issues (FERC Docket RM26-4 and AD26-7). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives.
Discussed the Cybersecurity and Information Security Agencys (CISA) work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for S. 2983, the Protecting America from Cyber Threats Act (all provisions), to reauthorize the Cybersecurity Information Security Act of 2015 (CISA 2015). Discussed support for a replacement to the Critical Infrastructure Partnership Advisory Council at the Department of Homeland Security to facilitate interaction between governmental entities and representatives from the community of critical infrastructure owners and operators. (no legislation). Discussed support for H.R. 7258, the Energy Emergency Leadership Act, to elevate the Department of Energys energy emergency and cybersecurity responsibilities by requiring those critical functions to be led by a Senate-confirmed Assistant Secretary (all provisions). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 2072, the Build More Hydro Act, to require the Federal Energy Regulatory Commission to extend the period during which licensees are required to commence construction of certain hydropower projects (all provisions). Discussed H.R. 7940, the Safeguarding Aquatic Fisheries and Ecosystem (SAFE) Pathways Act, to amend the Federal Power Act to require the consideration of invasive species when prescribing fishways. Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed the role of grid enhancing technologies in transmission and virtual power plants (no legislation). Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed H.R. 7977, the transmission provisions in the Energy Bills Relief Act. Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 3947, the REWIRE Act, section 3, to provide categorical exclusions for transmission projects that increase grid capacity in existing rights-of-way by reconductoring, using grid enhancing technologies, and deploying energy storage, and section 4, to increase return on equity for reconductoring using advanced conductors. Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Discussed H.R. 7329, the Fighting for Reliable Energy and Ending Doubt for Open Markets (FREEDOM) Act, to amend the Energy Act of 2020, the Geothermal Steam Act of 1970, the Energy Policy Act of 2005, and the Mineral Leasing Act to streamline the leasing and permitting processes of federal agencies for certain energy and mineral projects, to clarify federal authorization requirements for certain projects on non-federal land, to establish enforceable federal authorization timelines and expedited judicial remedies, to limit federal actions halting fully permitted projects, to create a de-risking compensation program. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed draft legislation, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed Light Up Navajo project to get electricity to unserved families of the Navajo Nation (no legislation). Discussed ongoing grid hardening activities by public power utilities and needed additional investments (no legislation). Discussed potential federal funding for critical infrastructure hardening. Discussed the impact tariffs are having on public power utilities (no legislation). Discussed the impact of supply chain issues on public power utilities (no legislation). Discussed the impact from data centers on electricity prices to customers in communities that dont have data centers (FERC Docket RM26-4). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives. Discussed wholesale electricity market development efforts in the West. Discussed the public power business model and FERCs jurisdiction over public power utilities under the Federal Power Act.
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.
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/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 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.
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 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.
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.
To provide for a memorandum of understanding to address the impacts of a certain record of decision on the Upper Colorado River Basin Fund.
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the importance of maintaining adequate staffing levels at the Power Marketing Administrations (no legislation). Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund. Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed support for H.R. 1001, to provide for a memorandum of understanding to address the impacts of a certain record of decision on the Upper Colorado River Basin Fund. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed draft legislation to amend the Forest Land Policy and Management Act (P.L. 94-579) to amend strict liability caps for wildfires on federal lands.
Water Systems PFAS Liability Protection 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 wastewater 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 support for H.R. 3898, the PERMIT Act, to improve the permitting process for infrastructure projects under the Clean Water Act. Discussed the provision regarding nationwide permitting and the determination of the appropriate acreage threshold for discharges into Waters of the US (WOTUS) and the provision regarding the 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 H.R. 1267, the Water System PFAS Liability Protection Act, and the need for PFAS liability protection for electric utilities in addition to public water systems. Discussed S. Amdt. 3363 to S. 2296, the National Defense Authorization Act for Fiscal Year 2026, which would provide PFAS liability protection to public water systems and the need to include public power. Discussed support for H.R. 161, the New Source Review Permitting Improvement Act (all provisions). Discussed the need to define the term relatively permanent rather than leaving it open to interpretation. Also discussed the definition of continuous surface connection and the exclusion for waste treatment systems under the Waters of the U.S. definition. (Final Clarifying Definition of Waters of the United States, RIN 2040-AG44).
New Source Review Permitting Improvement 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 wastewater 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 support for H.R. 3898, the PERMIT Act, to improve the permitting process for infrastructure projects under the Clean Water Act. Discussed the provision regarding nationwide permitting and the determination of the appropriate acreage threshold for discharges into Waters of the US (WOTUS) and the provision regarding the 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 H.R. 1267, the Water System PFAS Liability Protection Act, and the need for PFAS liability protection for electric utilities in addition to public water systems. Discussed S. Amdt. 3363 to S. 2296, the National Defense Authorization Act for Fiscal Year 2026, which would provide PFAS liability protection to public water systems and the need to include public power. Discussed support for H.R. 161, the New Source Review Permitting Improvement Act (all provisions). Discussed the need to define the term relatively permanent rather than leaving it open to interpretation. Also discussed the definition of continuous surface connection and the exclusion for waste treatment systems under the Waters of the U.S. definition. (Final Clarifying Definition of Waters of the United States, RIN 2040-AG44).
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).
POWER 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 S. 1429/H.R. 164, the Promoting Opportunities to Widen Electrical Resilience (POWER) Act, 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 opposition to the repeal of the Stafford Act (no legislation). Provided feedback to 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.
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).
Southwestern Power Administration Fund Establishment Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed support for agency actions to expedite environmental reviews under NEPA, the Endangered Species Act, and National Historic Preservation Act to reduce the risk of wildfires. Discussed strict liability caps for wildfires on federal lands under the Forest Land Policy and Management Act (P.L. 94-579). Discussed the need for more consistency of land management practices at federal land management agencies, such as U.S. Forest Service and the Bureau of Land Management. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions).
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 S. 1429/H.R. 164, the Promoting Opportunities to Widen Electrical Resilience (POWER) Act, 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 opposition to the repeal of the Stafford Act (no legislation). Provided feedback to 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.
Help Hoover Dam Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed support for agency actions to expedite environmental reviews under NEPA, the Endangered Species Act, and National Historic Preservation Act to reduce the risk of wildfires. Discussed strict liability caps for wildfires on federal lands under the Forest Land Policy and Management Act (P.L. 94-579). Discussed the need for more consistency of land management practices at federal land management agencies, such as U.S. Forest Service and the Bureau of Land Management. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions).
Help Hoover Dam Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the importance of maintaining adequate staffing levels at the Power Marketing Administrations (no legislation). Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund. Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed support for H.R. 1001, to provide for a memorandum of understanding to address the impacts of a certain record of decision on the Upper Colorado River Basin Fund. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed draft legislation to amend the Forest Land Policy and Management Act (P.L. 94-579) to amend strict liability caps for wildfires on federal lands.
Reliable Power Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed CISAs work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed concerns with the creation of additional cyber incident reporting requirements for electric utilities (no legislation). Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Also discussed extending the availability of existing funds and qualifications for awards. Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities. Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616, the Reliable Power Act, to give the Federal Energy Regulatory Commission (FERC) the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 3843, the Baseline Reliability Protection Act (all provisions), to prohibit retirements of baseload electric generating units in any area that is served by a Regional Transmission Organization or an Independent System Operator and that the North American Electric Reliability Corporation categorizes as at elevated risk or high risk of electricity supply shortfalls. Discussed resource adequacy issues and the importance of grid reliability (no legislation). Discussed H.R. 3699, the Energy Choice Act, to prohibit states or local governments from prohibiting or limiting the connection, reconnection, modification, installation, transportation, distribution, or expansion of an energy service based on the type or source of energy to be delivered (all provisions). Discussed how public power utilities, both transmission owners and transmission dependent, interact with FERC, participate in wholesale electricity markets, and other regional planning bodies (no legislation). Discussed the Department of Energys Speed to Power Initiative and the importance of resource adequacy for grid reliability. Discussed the impact tariffs are having on public power utilities (no legislation).
Reliable Power Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed potential legislation regarding the Energy Threat Analysis Center and obstacles to increased public power participation. Discussed support for the reauthorization of the Cybersecurity and Information Security Act of 2015 (passed as Division N of P.L. 114-113) and provisions to maintain public power utilities inclusion in the definition of private entity in section 102(15)(B) and maintaining public power utilities inclusion in section 104(B) - Exemption from Disclosure. Discussed the urgent need for a replacement for the public disclosure exemptions that were provided under the Critical Infrastructure Partnership Advisory Council to facilitate information sharing at Electricity Subsector Coordinating Council meetings (no legislation). Discussed CISAs work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for S. 1337, the Cybersecurity Information Sharing Extension Act (all provisions). Discussed support for H.R. 5079, the Widespread Information Management for the Welfare of Infrastructure and Government Act (all provisions). Discussed concerns with the creation of additional cyber incident reporting requirements for electric utilities (no legislation). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed support of H.R. 3657, the Hydropower Licensing Transparency Act, to direct the Federal Energy Regulatory Commission (FERC) to report annually to Congress on the status of the relicensing process for each application for a renewed hydropower dam license. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, from the 118th Congress, which would have expanded the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would have exempted Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed grid-enhancing technologies (GETS) and interconnection queue reform. Also discussed the need to ensure savings related to GETS benefits public power utilities and their customers (no bill). Discussed support for H.R. 3616, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Provided feedback on a draft bill to create a new must consider provision under section 111(d) of the Public Utility Regulatory Policy Act that would seek to create interconnection procedures to support microgrids. Discussed public powers concerns about transmission affordability, including transmission incentives. Discussed FERCs concerns about resource adequacy and the results of recent capacity auctions, including issues in Docket AD25-7. Discussed the importance of reliability, including coordination between the gas and electricity sectors. Discussed the North American Electric Reliability Corporations (NERC) electric reliability standards development procedures and the impact of FERC Order No. 907 (directing modifications to NERCs critical infrastructure protection standards) on the prioritization of NERCs standards development work. Discussed the importance of the Tennessee Valley Authority in providing affordable and reliable power to the Tennessee Valley.
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 wastewater 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 support for H.R. 3898, the PERMIT Act, to improve the permitting process for infrastructure projects under the Clean Water Act. Discussed the provision regarding nationwide permitting and the determination of the appropriate acreage threshold for discharges into Waters of the US (WOTUS) and the provision regarding the 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 H.R. 1267, the Water System PFAS Liability Protection Act, and the need for PFAS liability protection for electric utilities in addition to public water systems. Discussed S. Amdt. 3363 to S. 2296, the National Defense Authorization Act for Fiscal Year 2026, which would provide PFAS liability protection to public water systems and the need to include public power. Discussed support for H.R. 161, the New Source Review Permitting Improvement Act (all provisions). Discussed the need to define the term relatively permanent rather than leaving it open to interpretation. Also discussed the definition of continuous surface connection and the exclusion for waste treatment systems under the Waters of the U.S. definition. (Final Clarifying Definition of Waters of the United States, RIN 2040-AG44).
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).
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).
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).
ePermit Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the Environmental Protection Agencys (EPA) efforts to review the legacy coal combustion residuals rulemakings, including compliance extension deadlines for coal combustion residual management units, as well as potential updates to the legacy rule risk assessment and support for state CCR permit programs (Docket No. EPA-HQ-OLEM-2020-0107). Discussed H.R. 4875, the Coal Ash for American Infrastructure Act (all provisions). Discussed the need for the development of a federal coal combustion residuals (CCR) permitting program, the timely review and approval of state CCR programs by EPA, and support for the beneficial reuse of CCRs. Discussed the need for EPA to develop a CCR program that allows for site-specific, risk-based considerations and promotes the beneficial use of CCRs (no legislation). Discussed support for H.R. 4776, the SPEED Act, to reform permitting processes under NEPA (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. 573, Studying NEPAs Impact on Projects Act, to direct the Council on Environmental Quality (CEQ) to annually report on the impact of NEPA on projects that require NEPA review. CEQ must publish the report on its website and submit it to certain congressional committees.
Fix Our Forests Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed support for agency actions to expedite environmental reviews under NEPA, the Endangered Species Act, and National Historic Preservation Act to reduce the risk of wildfires. Discussed strict liability caps for wildfires on federal lands under the Forest Land Policy and Management Act (P.L. 94-579). Discussed the need for more consistency of land management practices at federal land management agencies, such as U.S. Forest Service and the Bureau of Land Management. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions).
Fix Our Forests Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed 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.
Fix Our Forests Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the importance of maintaining adequate staffing levels at the Power Marketing Administrations (no legislation). Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund. Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed support for H.R. 1001, to provide for a memorandum of understanding to address the impacts of a certain record of decision on the Upper Colorado River Basin Fund. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed draft legislation to amend the Forest Land Policy and Management Act (P.L. 94-579) to amend strict liability caps for wildfires on federal lands.
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).
SPEED Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the Environmental Protection Agencys (EPA) efforts to review the legacy coal combustion residuals rulemakings, including compliance extension deadlines for coal combustion residual management units, as well as potential updates to the legacy rule risk assessment and support for state CCR permit programs (Docket No. EPA-HQ-OLEM-2020-0107). Discussed H.R. 4875, the Coal Ash for American Infrastructure Act (all provisions). Discussed the need for the development of a federal coal combustion residuals (CCR) permitting program, the timely review and approval of state CCR programs by EPA, and support for the beneficial reuse of CCRs. Discussed the need for EPA to develop a CCR program that allows for site-specific, risk-based considerations and promotes the beneficial use of CCRs (no legislation). Discussed support for H.R. 4776, the SPEED Act, to reform permitting processes under NEPA (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. 573, Studying NEPAs Impact on Projects Act, to direct the Council on Environmental Quality (CEQ) to annually report on the impact of NEPA on projects that require NEPA review. CEQ must publish the report on its website and submit it to certain congressional committees.
Coal Ash for American Infrastructure Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the Environmental Protection Agencys (EPA) efforts to review the legacy coal combustion residuals rulemakings, including compliance extension deadlines for coal combustion residual management units, as well as potential updates to the legacy rule risk assessment and support for state CCR permit programs (Docket No. EPA-HQ-OLEM-2020-0107). Discussed H.R. 4875, the Coal Ash for American Infrastructure Act (all provisions). Discussed the need for the development of a federal coal combustion residuals (CCR) permitting program, the timely review and approval of state CCR programs by EPA, and support for the beneficial reuse of CCRs. Discussed the need for EPA to develop a CCR program that allows for site-specific, risk-based considerations and promotes the beneficial use of CCRs (no legislation). Discussed support for H.R. 4776, the SPEED Act, to reform permitting processes under NEPA (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. 573, Studying NEPAs Impact on Projects Act, to direct the Council on Environmental Quality (CEQ) to annually report on the impact of NEPA on projects that require NEPA review. CEQ must publish the report on its website and submit it to certain congressional committees.
Studying NEPA’s Impact on Projects Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the Environmental Protection Agencys (EPA) efforts to review the legacy coal combustion residuals rulemakings, including compliance extension deadlines for coal combustion residual management units, as well as potential updates to the legacy rule risk assessment and support for state CCR permit programs (Docket No. EPA-HQ-OLEM-2020-0107). Discussed H.R. 4875, the Coal Ash for American Infrastructure Act (all provisions). Discussed the need for the development of a federal coal combustion residuals (CCR) permitting program, the timely review and approval of state CCR programs by EPA, and support for the beneficial reuse of CCRs. Discussed the need for EPA to develop a CCR program that allows for site-specific, risk-based considerations and promotes the beneficial use of CCRs (no legislation). Discussed support for H.R. 4776, the SPEED Act, to reform permitting processes under NEPA (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. 573, Studying NEPAs Impact on Projects Act, to direct the Council on Environmental Quality (CEQ) to annually report on the impact of NEPA on projects that require NEPA review. CEQ must publish the report on its website and submit it to certain congressional committees.
AI Fraud Accountability Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed CISAs work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed concerns with the creation of additional cyber incident reporting requirements for electric utilities (no legislation). Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Also discussed extending the availability of existing funds and qualifications for awards. Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities. Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616, the Reliable Power Act, to give the Federal Energy Regulatory Commission (FERC) the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 3843, the Baseline Reliability Protection Act (all provisions), to prohibit retirements of baseload electric generating units in any area that is served by a Regional Transmission Organization or an Independent System Operator and that the North American Electric Reliability Corporation categorizes as at elevated risk or high risk of electricity supply shortfalls. Discussed resource adequacy issues and the importance of grid reliability (no legislation). Discussed H.R. 3699, the Energy Choice Act, to prohibit states or local governments from prohibiting or limiting the connection, reconnection, modification, installation, transportation, distribution, or expansion of an energy service based on the type or source of energy to be delivered (all provisions). Discussed how public power utilities, both transmission owners and transmission dependent, interact with FERC, participate in wholesale electricity markets, and other regional planning bodies (no legislation). Discussed the Department of Energys Speed to Power Initiative and the importance of resource adequacy for grid reliability. Discussed the impact tariffs are having on public power utilities (no legislation).
Southwestern Power Administration Fund Establishment Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed support for agency actions to expedite environmental reviews under NEPA, the Endangered Species Act, and National Historic Preservation Act to reduce the risk of wildfires. Discussed strict liability caps for wildfires on federal lands under the Forest Land Policy and Management Act (P.L. 94-579). Discussed the need for more consistency of land management practices at federal land management agencies, such as U.S. Forest Service and the Bureau of Land Management. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions).
POWER 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 S. 1429/H.R. 164, the Promoting Opportunities to Widen Electrical Resilience (POWER) Act, 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 opposition to the repeal of the Stafford Act (no legislation). Provided feedback to 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.
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.
Fix Our Forests Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the importance of maintaining adequate staffing levels at the Power Marketing Administrations (no legislation). Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund. Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed support for H.R. 1001, to provide for a memorandum of understanding to address the impacts of a certain record of decision on the Upper Colorado River Basin Fund. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed draft legislation to amend the Forest Land Policy and Management Act (P.L. 94-579) to amend strict liability caps for wildfires on federal lands.
Fix Our Forests Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed support for agency actions to expedite environmental reviews under NEPA, the Endangered Species Act, and National Historic Preservation Act to reduce the risk of wildfires. Discussed strict liability caps for wildfires on federal lands under the Forest Land Policy and Management Act (P.L. 94-579). Discussed the need for more consistency of land management practices at federal land management agencies, such as U.S. Forest Service and the Bureau of Land Management. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions).
Help Hoover Dam Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the importance of maintaining adequate staffing levels at the Power Marketing Administrations (no legislation). Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund. Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed support for H.R. 1001, to provide for a memorandum of understanding to address the impacts of a certain record of decision on the Upper Colorado River Basin Fund. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed draft legislation to amend the Forest Land Policy and Management Act (P.L. 94-579) to amend strict liability caps for wildfires on federal lands.
Help Hoover Dam Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed support for agency actions to expedite environmental reviews under NEPA, the Endangered Species Act, and National Historic Preservation Act to reduce the risk of wildfires. Discussed strict liability caps for wildfires on federal lands under the Forest Land Policy and Management Act (P.L. 94-579). Discussed the need for more consistency of land management practices at federal land management agencies, such as U.S. Forest Service and the Bureau of Land Management. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions).
National Defense Authorization Act for Fiscal Year 2026
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 wastewater 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 support for H.R. 3898, the PERMIT Act, to improve the permitting process for infrastructure projects under the Clean Water Act. Discussed the provision regarding nationwide permitting and the determination of the appropriate acreage threshold for discharges into Waters of the US (WOTUS) and the provision regarding the 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 H.R. 1267, the Water System PFAS Liability Protection Act, and the need for PFAS liability protection for electric utilities in addition to public water systems. Discussed S. Amdt. 3363 to S. 2296, the National Defense Authorization Act for Fiscal Year 2026, which would provide PFAS liability protection to public water systems and the need to include public power. Discussed support for H.R. 161, the New Source Review Permitting Improvement Act (all provisions). Discussed the need to define the term relatively permanent rather than leaving it open to interpretation. Also discussed the definition of continuous surface connection and the exclusion for waste treatment systems under the Waters of the U.S. definition. (Final Clarifying Definition of Waters of the United States, RIN 2040-AG44).
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. 3898, the PERMIT Act, to improve the permitting process for infrastructure projects under the Clean Water Act, the provision regarding nationwide permitting and the determination of the appropriate acreage threshold for discharges into WOTUS, and the provision regarding section 18 statutory exclusion from the regulatory definition of WOTUS for waste treatment systems. Discussed support for H.R. 161, the New Source Review Permitting Improvement Act (all provisions). Discussed H.R. 9855, the Certainty and Uniform Reviews for Reliable Energy and Transmission (CERTAIN) Act, to amend the Federal Water Pollution Control Act to make certain reforms with respect to permits and licenses under such act. Specifically discussed amending the Clean Water Act section 401 water quality certification process. Discussed support for H.R. 9855, the CERTAIN Act.
Discussed concerns with the Federal Communications Commissions (FCC) Notice of Proposed Rulemaking (FCC WC Docket 25-253) that seeks to use section 253 of the Communications Act to regulate public power pole attachments in contravention of the municipal exemption in section 224 of the Communications Act from FCC regulation of public power pole attachments.
Discussed the need for the U.S. Forest Service and Department of Interior to use existing authorities under section 512 of the Federal Land Policy and Management Act to allow electric utilities to better implement wildfire risk reduction. Discussed support for changes in the managers amendment to H.R. 9497, the Water Resources Development Act of 2026, to clarify that a new Office of Water Supply at the Army Corps of Engineers responsibilities are carried out in a manner that is consistent with authorized hydropower purposes at Corps projects (section 101). Discussed H.R. 9637, the Protecting Columbia River Salmon Act of 2026 to protect salmon from sea lion predation (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 an amendment to reinforce the municipal exemption in section 224 of the Communications Act of 1934, as amended, to 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 support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed the need for action on categorical exclusions for vegetation management along power line corridors. Also discussed strict liability for utilities operating on public lands for wildfires. Discussed the importance of the federal Power Marketing Administrations that provide federal hydropower to public power utilities and opposition to any attempts to privatize them in whole or in part. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions). Discussed support for the acting commissioner of the Bureau of Reclamation to release funds in the Colorado River Dam Fund for the acquisition of wide head turbines at Hoover Dam as directed to in the report language accompanying H.R. 6938, the Energy & Water Development Appropriations Act, 2026. Discussed the need to exempt the Boulder Canyon Dam Project from the Federal Lands Recreation Enhancement Act (P.L. 108‑447), which would give the Bureau of Reclamation the ability to collect entry fees at Hoover Dam (no legislation).
Discussed support for 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. 3898, the PERMIT Act, to improve the permitting process for infrastructure projects under the Clean Water Act, the provision regarding nationwide permitting and the determination of the appropriate acreage threshold for discharges into WOTUS, and the provision regarding section 18 statutory exclusion from the regulatory definition of WOTUS for waste treatment systems. Discussed support for H.R. 161, the New Source Review Permitting Improvement Act (all provisions). Discussed H.R. 1267, the PFAS Water Systems Liability Act, regarding how utilities are passive receivers of PFAS. Discussed the technology-based effluent limitations and standards for the Steam Electric Power Generating Point Source that the Environmental Protection Agency (EPA) promulgated in 2024 (RIN: 2040-AG41). Discussed EPAs proposed rule to approve state implementation plans for the 2015 ozone ambient air quality standards based on the agencys conclusion that 10 states dont contribute to downwind state nonattainment (EPA-HQ-OAR-2025-0192).
Discussed the Cybersecurity and Information Security Agencys (CISA) work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed support for S. 2983, the Protecting America from Cyber Threats Act (all provisions), to reauthorize the Cybersecurity Information Security Act of 2015 (CISA 2015). Discussed support for a replacement to the Critical Infrastructure Partnership Advisory Council at the Department of Homeland Security to facilitate interaction between governmental entities and representatives from the community of critical infrastructure owners and operators. (no legislation). Discussed support for H.R. 7258, the Energy Emergency Leadership Act, to elevate the Department of Energys energy emergency and cybersecurity responsibilities by requiring those critical functions to be led by a Senate-confirmed Assistant Secretary (all provisions). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 2072, the Build More Hydro Act, to require the Federal Energy Regulatory Commission to extend the period during which licensees are required to commence construction of certain hydropower projects (all provisions). Discussed H.R. 7940, the Safeguarding Aquatic Fisheries and Ecosystem (SAFE) Pathways Act, to amend the Federal Power Act to require the consideration of invasive species when prescribing fishways. Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed the role of grid enhancing technologies in transmission and virtual power plants (no legislation). Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed H.R. 7977, the transmission provisions in the Energy Bills Relief Act. Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Discussed S. 3947, the REWIRE Act, section 3, to provide categorical exclusions for transmission projects that increase grid capacity in existing rights-of-way by reconductoring, using grid enhancing technologies, and deploying energy storage, and section 4, to increase return on equity for reconductoring using advanced conductors. Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Discussed H.R. 7329, the Fighting for Reliable Energy and Ending Doubt for Open Markets (FREEDOM) Act, to amend the Energy Act of 2020, the Geothermal Steam Act of 1970, the Energy Policy Act of 2005, and the Mineral Leasing Act to streamline the leasing and permitting processes of federal agencies for certain energy and mineral projects, to clarify federal authorization requirements for certain projects on non-federal land, to establish enforceable federal authorization timelines and expedited judicial remedies, to limit federal actions halting fully permitted projects, to create a de-risking compensation program. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed draft legislation, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed Light Up Navajo project to get electricity to unserved families of the Navajo Nation (no legislation). Discussed ongoing grid hardening activities by public power utilities and needed additional investments (no legislation). Discussed potential federal funding for critical infrastructure hardening. Discussed the impact tariffs are having on public power utilities (no legislation). Discussed the impact of supply chain issues on public power utilities (no legislation). Discussed the impact from data centers on electricity prices to customers in communities that dont have data centers (FERC Docket RM26-4). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives. Discussed wholesale electricity market development efforts in the West. Discussed the public power business model and FERCs jurisdiction over public power utilities under the Federal Power Act.
Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed support for agency actions to expedite environmental reviews under the National Environmental Policy Act, Endangered Species Act, and National Historic Preservation Act to reduce the risk of wildfires. Discussed strict liability caps for wildfires on federal lands under the Forest Land Policy and Management Act (P.L. 94-579). Discussed the need for more consistency of land management practices at federal land management agencies, such as U.S. Forest Service and the Bureau of Land Management. Discussed support for comprehensive vegetation management practices along power line corridors on federal lands. Discussed Bonneville Power Administrations role in transmission in the Pacific Northwest (no legislation). Discussed the federal hydropower system in the Pacific Northwest (no legislation). Discussed support for adequate staffing levels at the federal Power Marketing Administrations (no legislation).
Discussed 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).
Discussed support for H.R. 4776, the SPEED Act, to reform permitting processes under the National Environmental Policy Act (all provisions). Discussed support for H.R. 4503, the ePermit Act, to digitize the federal permitting process for environmental reviews. Discussed support of reforms to the Endangered Species Act that would change the definition of habitat (no legislation). Discussed how the Endangered Species Act impacts energy infrastructure projects (no legislation). Discussed H.R. 1897, the Endangered Species Act Amendments of 2025 (all provisions). Discussed the Environmental Protection Agencys reconsideration of the 2024 Coal Combustion Residuals Legacy rule regarding the disposal of coal combustion residuals and impoundments (RIN: 2050-AH39).
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, U.S. Forest Service, White House Office
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2025 · fourth_quarter · Q4
Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed CISAs work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed concerns with the creation of additional cyber incident reporting requirements for electric utilities (no legislation). Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Also discussed extending the availability of existing funds and qualifications for awards. Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities. Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616, the Reliable Power Act, to give the Federal Energy Regulatory Commission (FERC) the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 3843, the Baseline Reliability Protection Act (all provisions), to prohibit retirements of baseload electric generating units in any area that is served by a Regional Transmission Organization or an Independent System Operator and that the North American Electric Reliability Corporation categorizes as at elevated risk or high risk of electricity supply shortfalls. Discussed resource adequacy issues and the importance of grid reliability (no legislation). Discussed H.R. 3699, the Energy Choice Act, to prohibit states or local governments from prohibiting or limiting the connection, reconnection, modification, installation, transportation, distribution, or expansion of an energy service based on the type or source of energy to be delivered (all provisions). Discussed how public power utilities, both transmission owners and transmission dependent, interact with FERC, participate in wholesale electricity markets, and other regional planning bodies (no legislation). Discussed the Department of Energys Speed to Power Initiative and the importance of resource adequacy for grid reliability. Discussed the impact tariffs are having on public power utilities (no legislation).
Discussed possible regulations to implement section 26 USC 7701(a)(51), prohibited foreign entity debt test. 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 H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed support for agency actions to expedite environmental reviews under NEPA, the Endangered Species Act, and National Historic Preservation Act to reduce the risk of wildfires. Discussed strict liability caps for wildfires on federal lands under the Forest Land Policy and Management Act (P.L. 94-579). Discussed the need for more consistency of land management practices at federal land management agencies, such as U.S. Forest Service and the Bureau of Land Management. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions).
Discussed support 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
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2025 · third_quarter · Q3
Discussed potential legislation regarding the Energy Threat Analysis Center and obstacles to increased public power participation. Discussed support for the reauthorization of the Cybersecurity and Information Security Act of 2015 (passed as Division N of P.L. 114-113) and provisions to maintain public power utilities inclusion in the definition of private entity in section 102(15)(B) and maintaining public power utilities inclusion in section 104(B) - Exemption from Disclosure. Discussed the urgent need for a replacement for the public disclosure exemptions that were provided under the Critical Infrastructure Partnership Advisory Council to facilitate information sharing at Electricity Subsector Coordinating Council meetings (no legislation). Discussed CISAs work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for S. 1337, the Cybersecurity Information Sharing Extension Act (all provisions). Discussed support for H.R. 5079, the Widespread Information Management for the Welfare of Infrastructure and Government Act (all provisions). Discussed concerns with the creation of additional cyber incident reporting requirements for electric utilities (no legislation). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed support of H.R. 3657, the Hydropower Licensing Transparency Act, to direct the Federal Energy Regulatory Commission (FERC) to report annually to Congress on the status of the relicensing process for each application for a renewed hydropower dam license. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, from the 118th Congress, which would have expanded the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would have exempted Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed grid-enhancing technologies (GETS) and interconnection queue reform. Also discussed the need to ensure savings related to GETS benefits public power utilities and their customers (no bill). Discussed support for H.R. 3616, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Provided feedback on a draft bill to create a new must consider provision under section 111(d) of the Public Utility Regulatory Policy Act that would seek to create interconnection procedures to support microgrids. Discussed public powers concerns about transmission affordability, including transmission incentives. Discussed FERCs concerns about resource adequacy and the results of recent capacity auctions, including issues in Docket AD25-7. Discussed the importance of reliability, including coordination between the gas and electricity sectors. Discussed the North American Electric Reliability Corporations (NERC) electric reliability standards development procedures and the impact of FERC Order No. 907 (directing modifications to NERCs critical infrastructure protection standards) on the prioritization of NERCs standards development work. Discussed the importance of the Tennessee Valley Authority in providing affordable and reliable power to the Tennessee Valley.
Discussed the importance of maintaining adequate staffing levels at the Power Marketing Administrations (no legislation). Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund. Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed support for H.R. 1001, to provide for a memorandum of understanding to address the impacts of a certain record of decision on the Upper Colorado River Basin Fund. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed draft legislation to amend the Forest Land Policy and Management Act (P.L. 94-579) to amend strict liability caps for wildfires on federal lands.
Discussed the Environmental Protection Agencys (EPA) efforts to review the legacy coal combustion residuals rulemakings, including compliance extension deadlines for coal combustion residual management units, as well as potential updates to the legacy rule risk assessment and support for state CCR permit programs (Docket No. EPA-HQ-OLEM-2020-0107). Discussed H.R. 4875, the Coal Ash for American Infrastructure Act (all provisions). Discussed the need for the development of a federal coal combustion residuals (CCR) permitting program, the timely review and approval of state CCR programs by EPA, and support for the beneficial reuse of CCRs. Discussed the need for EPA to develop a CCR program that allows for site-specific, risk-based considerations and promotes the beneficial use of CCRs (no legislation). Discussed support for H.R. 4776, the SPEED Act, to reform permitting processes under NEPA (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. 573, Studying NEPAs Impact on Projects Act, to direct the Council on Environmental Quality (CEQ) to annually report on the impact of NEPA on projects that require NEPA review. CEQ must publish the report on its website and submit it to certain congressional committees.
Discussed opposition to H.R. 278, BROADBAND Leadership Act, to effectively gut the exemption in section 224 of the Communications Act of 1934, which prevents the Federal Communications Commission from regulating public power pole attachments.
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 wastewater 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 support for H.R. 3898, the PERMIT Act, to improve the permitting process for infrastructure projects under the Clean Water Act. Discussed the provision regarding nationwide permitting and the determination of the appropriate acreage threshold for discharges into Waters of the US (WOTUS) and the provision regarding the 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 H.R. 1267, the Water System PFAS Liability Protection Act, and the need for PFAS liability protection for electric utilities in addition to public water systems. Discussed S. Amdt. 3363 to S. 2296, the National Defense Authorization Act for Fiscal Year 2026, which would provide PFAS liability protection to public water systems and the need to include public power. Discussed support for H.R. 161, the New Source Review Permitting Improvement Act (all provisions). Discussed the need to define the term relatively permanent rather than leaving it open to interpretation. Also discussed the definition of continuous surface connection and the exclusion for waste treatment systems under the Waters of the U.S. definition. (Final Clarifying Definition of Waters of the United States, RIN 2040-AG44).
Filing targets: Environmental Protection Agency (EPA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Office of Management & Budget (OMB), SENATE, Treasury, Dept of
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2025 · second_quarter · Q2
Discussed 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 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 S. 1429/H.R. 164, the Promoting Opportunities to Widen Electrical Resilience (POWER) Act, 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 opposition to the repeal of the Stafford Act (no legislation). Provided feedback to 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.
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