SARAH CZUFIN MATHIAS

Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed possible funding for the Department of Energy (DOE) to assist manufacturers of distribution transformers in increasing their production (no legislation). Discussed the patchwork of cyber incident reporting requirements and concerns about harmonization, including the Cybersecurity and Infrastructure Security Agencys implementation of the Cyber Incident Reporting for Critical Infrastructure Act (CISA-2022-0010). Discussed support for H.R. 4045, the Hydropower Clean Energy Future Act (all provisions). Discussed support for S. 2994/H.R. 6653, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed concerns with Form EIA-112, Residential Utility Disconnections Survey. Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would exempt Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Provided feedback on draft legislation, the Rural Grid Resilience Act, to promote microgrids and grid resilience in rural communities. Discussed the price spike in PJMs 2024 Base Residual Auction and efforts by stakeholders to postpone PJMs 2025 Base Residual Auction. Discussed how the Federal Energy Regulatory Commissions (FERC) regulations impact public power communities despite most public power utilities not being subject to FERC ratemaking regulation. Discussed concerns with transmission affordability and rising transmission costs, and support for policies, such as joint ownership and eliminating unnecessary incentives, that would reduce transmission costs. Discussed concerns regarding the long lead times to interconnect new generation resources, and support for policies that prioritize interconnection for load-serving entities.

Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed H.R. 9083, the SECURE GRID Act, to amend the Energy Policy and Conservation Act to require states to include supporting the physical security, cybersecurity, and resilience of local distribution systems in State energy security plans (all provisions). Provided feedback on draft legislation to promote the deployment of virtual power plants. Provided feedback on draft legislation to help promote the development of renewable energy microgrids in rural communities. Discussed the need for the Department of Energy (DOE) to reduce the administrative burden for grants and other federal funding opportunities through DOE, especially for smaller, less-resourced utilities. Discussed how DOE could improve collaboration with electric utilities. Discussed support for S. 2994/H.R. 6653, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed support for S. 2356 from the 117th Congress, the Twenty-First Century Dams Act. Discussed concerns with Form EIA-112, Residential Utility Disconnections Survey. Discussed the need for permitting reform to help expedite the siting and permitting of energy projects to meet rising electricity demand. Discussed general support for permitting reform to help expedite the construction of energy infrastructure, including changes to the National Environmental Policy Act to streamline processes but not include transmission-related language that would expand FERCs jurisdiction over cost allocation and potentially saddle public power utilities with additional transmission costs. Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would exempt Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Discussed support for S. 4171, the Making Pipelines Accountable to Consumers and Taxpayers Act. Discussed concerns with H.R. 8032, the Low Income Household Water Assistance Program Establishment Act (all provisions).

Discussed concerns about the effect on public power utilities as counterparties in derivative transactions with banks as a result of increased capital requirements for large bank transactions with non-publicly traded entities under proposed rule, Regulatory Capital Rule: Large Banking Organizations and Banking Organizations with Significant Trading Activity (Docket ID: OCC-2023-0008, 88 Fed. Reg. 64028 (2023) and proposed rule, Regulatory Capital Rule: Risk-Based Capital Surcharges for Global Systemically Important Bank Holding Companies; System Risk Report (FR Y-15) (Docket No. R-1814, 88 Fed. Reg. 60385).

Discussed concerns with third-party efforts to remove the Lower Snake River Dams and the importance of hydropower (no bill). Discussed Columbia River Settlement Agreement and concerns with the potential impact of breaching the Lower Snake River dams on hydropower production, meeting clean energy goals, and grid reliability (no legislation). Discussed Columbia River Treaty negotiations. Discussed support for S. 3581/H.R. 6924, the Hydropower Delivery Rate-reduction Offset (HYDRO) Act. Discussed the issue of the assignment of inequitable costs by the Army Corps of Engineers to the Power Marketing Administrations and their customers. Discussed support for ensuring the Water Resources Development Act (no bill number) protects federal hydropower customers from costs issued by the Army Corps of Engineers for which they receive no benefit. Discussed language to make clear that the Power Marketing Administration Administrators retain full authority on setting rates in draft Water Resources Development Act legislation. Discussed the importance of preserving Power Marketing Administration rate making authority; the application of dam safety costs to state-of-the-art modifications; the Stockton Lake compromise on water supply and hydropower generation; and the study of power deauthorization at Willamette Valley projects in the context of future Water Resource Development Act legislation (no bill). Discussed concerns with sections 121(a) and 121(c) of H.R. 8812, the Water Resources Development Act, regarding the classification of authorized purposes at Corps projects and cost sharing. Also discussed an amendment to the legislation to create a pilot program for Corps projects in AZ, CA, and NV at which the secretary of the Army to declare water supply is an authorized purpose during drought emergencies. Discussed the importance of the federal Power Marketing Administrations that provide federal hydropower to public power utilities. Discussed growing threats to electric utilities from wildfires (no legislation). Discussed S. 4628, the Enhancing Mitigation and Building Effective Resilience Act (all provisions). Discussed H.R. 8160, the Breaking Irresponsible Energy and Commercial Habitats Act (all provisions). Discussed H.R. 8161, the Electric Ratepayer Funding Alternative Act (all provisions). Discussed H.R. 8159, the Abandoning Inconsistent and Rash Environmental Solutions Act (all provisions). Discussed H.R. 8156, the Queries Act (all provisions).

Discussed general support for the concepts included in draft legislation, the Rural Economic Development Loan Program Collateral Flexibility Act of 2024, and similar language in H.R. 8467, the Farm, Food, and National Security Act of 2024, to give the U.S. Department of Agriculture more flexibility to accept alternative forms of collateral for the Rural Economic Development Loan & Grant Program.

Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed efforts at the Department of Energy (DOE) to address the distribution transformer supply chain crisis. Discussed DOEs final energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they were improved from proposed standards. Discussed H.R. 4167, the Protecting Americas Distribution Transformer Supply Chain Act, to prevent DOE from proposing or enacting new energy efficiency standards for distribution transformers for five years. Discussed the Cybersecurity and Infrastructure Security Agency's Notice of Proposed Rulemaking to implement the requirements of the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (Docket Number: CISA-2022-0010) and the need to avoid duplicative reporting requirements. Discussed support for the Charging and Fueling Infrastructure Grant Program under Subtitle D, sec. 11401 of the Infrastructure Investment and Jobs Act (P.L. 115-58). Discussed support for the Department of Energy Grid Resilience and Innovation Partnerships (GRIP) Program (P.L. 117-58, sections 40101, 40103, and 40107). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed the importance of hydropower as a source of renewable energy for public power utilities. Discussed the importance of hydropower for grid reliability. Discussed support for H.R. 4045, the Hydropower Clean Energy Future Act (all provisions). Discussed S. 1521, the Community & Hydropower Improvement Act (all provisions). Discussed support for S. 2994/H.R. 6653, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed H.R. 5551/S. 2827, the BIG WIRES Act, to give the Federal Energy Regulatory Commission (FERC) the authority to require the expansion of transmission facilities for reliability and establish thresholds for interregional transfer capability (all provisions). Discussed H.R. 6747, the Clean Electricity and Transmission Acceleration Act of 2023 (CETA), to direct FERC to determine the existing electricity transfer capacity between regions and to establish minimum levels of transfer capabilities between each region, and to require each transmission planning region to coordinate with its neighbors to plan for the required interregional transmission (all provisions). Discussed the need for permitting reform to help expedite the siting and permitting of energy projects to meet emissions reduction goals. Discussed support for permitting reform to help expedite the construction of energy infrastructure (no bill), including changes to the National Environmental Policy Act to streamline processes but not include transmission-related language that would expand FERCs jurisdiction over cost allocation and potentially saddle public power utilities with additional transmission costs. Discussed the importance of joint ownership opportunities for public power utilities as new transmission projects are being built. Discussed how it could help reduce transmission costs for customers and build community support for transmission projects. Discussed amendment 8 to H.R. 7023, the Creating Confidence in Clean Water Permitting Act, which would make it more difficult and costly to permit certain electric transmission projects. Discussed S. 4027/H.R. 7786, the SPEED and Reliability Act of 2024 (section (2)(a)(D)), on the exemption of a facility as in the national interest from review under the National Environmental Policy Act. Discussed concerns with overly stringent Build America/Buy America standards in the Infrastructure Investment and Jobs Act (P.L. 117-58) and the impact those standards have on public power utilities ability to complete grant-funded projects. Discussed the need to increase product and asset availability, price transparency, accountability, and coordination between the natural gas and electric industries to ensure electric reliability (no legislation). Discussed how FERCs Order 1920 (Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17)) was a missed opportunity to deal with cost allocation issues and joint ownership of transmission projects. Discussed electric transmission costs, planning, and joint ownership, including FERCs Notice of Proposed Rulemaking, Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17). Discussed resource adequacy issues. Discussed Western markets. Discussed FERCs practice and procedure and generator interconnection issues, including implementation of Order 2023 (Docket No. RM22-14). Discussed power market mitigation for institutional investors (Docket No. AD24-60). Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort. Discussed S. 4171, the Making Pipelines Accountable to Consumers Act (all provisions). Discussed S. 3820, the Low Income Household Water Assistance Program Establishment Act (sections 2(b) and 2(g). Discussed the White Houses 150 Comeback Communities and public power utilities can better leverage programs and policies included in the Inflation Reduction Act.

AMERICAN PUBLIC POWER ASSOCIATION

AMERICAN PUBLIC POWER ASSOCIATION

AMERICAN PUBLIC POWER ASSOCIATION

AMERICAN PUBLIC POWER ASSOCIATION