Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page

9. Check if this filing amends a previously filed version of this report

LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.

15. General issue area code UTI

16. Specific lobbying issues

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.

17. House(s) of Congress and Federal agencies Check if None

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Energy - Dept of, Federal Energy Regulatory Commission (FERC), Treasury - Dept of

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

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LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.

15. General issue area code TAX

16. Specific lobbying issues

Discussed the importance of elective pay refundable energy tax credits included in the Inflation Reduction Act (Pub. Law 117-169) for public power investments in clean energy technologies to address climate change.

Discussed concerns with implementation of the domestic content requirements necessary to access elective pay provisions in the Inflation Reduction Act (Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702).

Discussed the likelihood of legislation to amend the tax treatment of municipal bonds.

Discussed implementation of 26 USC 45U, the existing nuclear tax credit.

Discussed support for direct pay of the nuclear investment tax credit (P.L. 117-169, sec. 13105).

Discussed support for adding direct pay to S. 1793/H.R. 5803, the Grid Resiliency Tax Credit Act.

Discussed possible changes to the three-year limit on customized commercial contracts under 16 CFR 1.141-7(f)(3) - private use rules for output facilities financed with tax-exempt bonds.

17. House(s) of Congress and Federal agencies Check if None

U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Treasury - Dept of, Energy - Dept of

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

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LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.

15. General issue area code NAT

16. Specific lobbying issues

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).

17. House(s) of Congress and Federal agencies Check if None

U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Energy - Dept of

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

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LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.

15. General issue area code CAW

16. Specific lobbying issues

Discussed the Environmental Protection Agency's proposed rules to regulate greenhouse gas emissions from power plants (EPA-HQ-OAR-2023-0072) and the potential impacts to public power utilities, as well as potential impact on affordability and reliability.

Discussed concerns with EPAs final rules to regulate greenhouse gas emissions from power plants (EPA-HQ-OAR-2023-0072) and the impact they will have on public power utilities, as well as on affordability and reliability.

Discussed the creation of a federal clean energy standard and the need for Congress to provide public power utilities with regulatory certainty.

Discussed S.J. Res. 92/H.R. Res. 177, a joint resolution providing for congressional disapproval of EPAs final greenhouse gas regulations for power plants.

Discussed EPAs efforts to obtain quality and useful emissions information in its Air Emissions Reporting (EPA-HQ-OAR-2004-0489).

17. House(s) of Congress and Federal agencies Check if None

U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Environmental Protection Agency (EPA)

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

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LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.

15. General issue area code BUD

16. Specific lobbying issues

Discussed support for funding for the Low Income Home Energy Assistance Program in Fiscal Year 2025 Labor, Health, and Human Services Appropriations Act (not yet drafted legislation).

Discussed support for funding through the appropriations for DOE to help address labor and materials shortages for distribution transformers (no bill).

Discussed funding being included in the fiscal year 2025 Energy and Water Development Appropriations bill for the Defense Production authorities to help address the distribution transformer supply chain crisis (no bill).

Discussed the effects of sequestration under the Budget Control Act and Statutory Pay as You Go Act on public power utilities.

Discussed the possible waiver of the sequestration provisions of the Statutory Pay as You Go Act (2 USC 931) as relates to the American Rescue Plan Act (P.L. 117-7).

Discussed funding for federal grants to states for the federal Coal Combustions Residuals Permit Program and for language to direct EPA to expedite the review and approval state permit programs.

17. House(s) of Congress and Federal agencies Check if None

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

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LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.

15. General issue area code BAN

16. Specific lobbying issues

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).

17. House(s) of Congress and Federal agencies Check if None

U.S. SENATE

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

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LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.

15. General issue area code AGR

16. Specific lobbying issues

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.

17. House(s) of Congress and Federal agencies Check if None

U.S. SENATE

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

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LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.

15. General issue area code ENG

16. Specific lobbying issues

Discussed support for S. 870, the ADVANCE Act (all provisions) to promote advanced nuclear technologies.

Discussed the need for a solution for nuclear waste storage (no bill).

17. House(s) of Congress and Federal agencies Check if None

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

​

LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.

15. General issue area code ENV

16. Specific lobbying issues

Discussed concerns with EPAs coal ash regulations (Hazardous and Solid Waste Management System: Disposal of Coal Combustion Residuals from Electric Generating Units; Legacy CCR Surface Impoundments). Also discussed the need for EPA to finalize the federal Coal Combustion Residuals Program.

Discussed H.J. Res. 174/H.J. Res. 152, providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "Hazardous and Solid Waste Management System: Disposal of Coal Combustion Residuals from Electric Utilities; Legacy CCR Surface Impoundments."

17. House(s) of Congress and Federal agencies Check if None

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

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LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.

15. General issue area code CSP

16. Specific lobbying issues

Discussed language in H.R. 8818, the American Privacy Rights Act, that removes U.S. territories from the list of entities that are excluded from the bills provisions.

17. House(s) of Congress and Federal agencies Check if None

U.S. HOUSE OF REPRESENTATIVES

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

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LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.

15. General issue area code DIS

16. Specific lobbying issues

Discussed support for H.R. 2672, the FEMA Loan Interest Payment Relief Act.

17. House(s) of Congress and Federal agencies Check if None

U.S. HOUSE OF REPRESENTATIVES

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

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Information Update Page - Complete ONLY where registration information has changed.

20. Client new address

21. Client new principal place of business (if different than line 20)

22. New General description of client’s business or activities

LOBBYIST UPDATE

23. Name of each previously reported individual who is no longer expected to act as a lobbyist for the client

ISSUE UPDATE

24. General lobbying issue that no longer pertains

AFFILIATED ORGANIZATIONS

25. Add the following affiliated organization(s)

Internet Address:

26. Name of each previously reported organization that is no longer affiliated with the registrant or client

FOREIGN ENTITIES

27. Add the following foreign entities:

28. Name of each previously reported foreign entity that no longer owns, or controls, or is affiliated with the registrant, client or affiliated organization

CONVICTIONS DISCLOSURE

29. Have any of the lobbyists listed on this report been convicted in a Federal or State Court of an offense involving bribery, extortion, embezzlement, an illegal kickback, tax evasion, fraud, a conflict of interest, making a false statement, perjury, or money laundering?
No Yes