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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
Address1 | 4301 WILSON BOULEVARD |
Address2 | |
City | ARLINGTON |
State | VA |
Zip Code | 22203 |
Country | USA |
3. Principal place of business (if different than line 2)
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State | |
Zip Code | |
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5. Senate ID# 28515-12
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6. House ID# 316650000
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TYPE OF REPORT | 8. Year | 2014 |
Q1 (1/1 - 3/31) | Q2 (4/1 - 6/30) | Q3 (7/1 - 9/30) | Q4 (10/1 - 12/31) |
9. Check if this filing amends a previously filed version of this report
10. Check if this is a Termination Report | Termination Date | |
11. No Lobbying Issue Activity |
INCOME OR EXPENSES - YOU MUST complete either Line 12 or Line 13 | |||||||||
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12. Lobbying | 13. Organizations | ||||||||
INCOME relating to lobbying activities for this reporting period was: | EXPENSE relating to lobbying activities for this reporting period were: | ||||||||
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Provide a good faith estimate, rounded to the nearest $10,000, of all lobbying related income for the client (including all payments to the registrant by any other entity for lobbying activities on behalf of the client). | 14. REPORTING Check box to indicate expense accounting method. See instructions for description of options. | ||||||||
Method A.
Reporting amounts using LDA definitions only
Method B. Reporting amounts under section 6033(b)(8) of the Internal Revenue Code Method C. Reporting amounts under section 162(e) of the Internal Revenue Code |
Signature | Digitally Signed By: Mike Whelan, Director Government Relations |
Date | 01/20/2015 |
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
H.J. Res. 124: Continuing Appropriations Resolution, 2015
Ensuring co-op related programs are maintained at appropriate levels.
H.R. 83 Consolidated and Further Continuing Appropriations Act, 2015
H.R. 634: Business Risk Mitigation and Price Stabilization Act of 2013
Clarifies the end-user exemption from margin requirement.
H.R. 4267: The Commodity Delivery Relief Act, to clarify that intended physically-settled, nonfinancial commodities contracts should be exempt from the definition of swap under the Dodd-Frank Act.
H.R. 4413: Customer Protection and End User Relief Act
To reauthorize the Commodity Futures Trading Commission operations and includes certain end-user exemptions from requirements under the Dodd-Frank Act.
H.R. 4800, S. 2389: Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2015
Ensuring RUS electric loans are available to meet co-op borrowers financing needs.
P.L. 111-203: Issues related to the implementation of The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, including the end-user exemption from margin and clearing requirements.
S. 888: To provide end user exemptions from certain provisions of the Commodity Exchange Act and the Securities Exchange Act of 1934.
Issues related to rural broadband deployment and the Connect America Fund.
Issues related to the potential impact of the Administrations rulemaking on the Clean Power Plan on the Rural Utilities Service loan portfolio.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Kirk |
Johnson |
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John |
Cassady |
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Brian |
Cavey |
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Christine |
Heggem |
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Julie |
Barkemeyer |
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Tammy |
Embrey |
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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 BAN
16. Specific lobbying issues
H.J. Res. 124: Continuing Appropriations Resolution, 2015
Ensuring co-op related programs are maintained at appropriate levels.
H.R. 4871: TRIA Reform Act of 2014
Terrorism Risk Insurance Act reauthorizations.
S. 2244: Terrorism Risk Insurance Program Reauthorization Act of 2014
Terrorism Risk Insurance Act reauthorizations.
S. 1217: The Housing Finance Reform and Taxpayer Protection Act of 2013
Includes a clarification allowing Federal Home Loan Bank (FHLB) investments in National Rural Utilities Cooperative Finance Corporation (CFC) securities.
P.L. 111-203: Issues related to the implementation of The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, including the end-user exemption from margin and clearing requirements.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Kirk |
Johnson |
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Brian |
Cavey |
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Julie |
Barkemeyer |
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Bridgette |
Bourge |
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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 BUD
16. Specific lobbying issues
H.R. 4800, S. 2389: Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2015
Ensuring RUS electric loans are available to meet co-op borrowers financing needs.
H.R. 5013, S. 2499: Department of State, Foreign Operations, and Related Programs Appropriations Act, 2015
Maintain funding for USAID Cooperative Development Program.
Issues related to Department of Homeland Security programs and resources.
Issues related to Low-Income Home Energy Assistance Program (LIHEAP) Funding in the Labor HHS Appropriations Bill.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Kirk |
Johnson |
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John |
Cassady |
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Brian |
Cavey |
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Christine |
Heggem |
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Chris |
Stephen |
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Julie |
Barkemeyer |
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Montee |
Wynn |
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Tammy |
Embrey |
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Paul |
Gutierrez |
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Bridgette |
Bourge |
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Abbie |
Laugtug |
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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 CAW
16. Specific lobbying issues
H.R. 935: The Reducing Regulatory Burdens Act of 2013
Preventing duplicative regulation of pesticide application.
H.R. 3826, S. 1905: The Whitfield-Manchin Electricity Security and Affordability Act, legislation directing how EPA establishes GHG performance standards for fossil fuel electric generating units.
H.R. 5078, S. 2496: Waters of the United States Regulatory Overreach Protection Act of 2014
Legislation to prohibit EPA and the U.S. Army Corps of Engineers from finalizing and enforcing the proposed rule entitled, Definition of Waters of the United States Under the Clean Water Act, issued on April 21, 2014.
Issues related to Clean Air Act enforcement relating to GHG regulations and new source performance standards for power plants.
Issues associated with the Administrations rulemaking on the Waters of the U.S. regulatory proposal.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Kirk |
Johnson |
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John |
Cassady |
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Brian |
Cavey |
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Christine |
Heggem |
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Montee |
Wynn |
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Julie |
Barkemeyer |
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Tammy |
Embrey |
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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 ENG
16. Specific lobbying issues
H.R. 271: Resolving Environmental and Grid Reliability Conflicts Act of 2013
Amendment to establish that if an electric co-op complies with a Department of Energy emergency order and due to such compliance environmental laws or regulations are violated, the electric co-op will be protected from agency penalties and third party law suits.
H.R. 1900: The Natural Gas Pipeline Permitting Reform Act
This bill would expedite the construction of interstate natural gas pipelines by providing for timely consideration of licenses, permits, and approvals required under federal law.
H.R. 2126, S. 2971: The Energy Efficiency Improvement Act of 2014
Title II of the bill includes provisions to improve and promote energy efficiency in buildings, and to permit the manufacture of large capacity (exceeding 75 gallons) electric resistance water heaters for demand response programs.
(Barkemeyer)
H.R. 4066, S. 1739: A bill to permit the continued manufacture of large capacity electric resistance water heaters for demand response programs.
S. 802: Sensible Environmental Protection Act of 2013
Preventing duplicative regulation of pesticide applications.
S. 1009: Chemical Safety Improvement Act
Issues related to PCB Use Authorizations under TSCA
S. 1020, S 1199: All-Of-The-Above Federal Building Energy Conservation Act of 2013
Legislation that repeals Section 433 of the 2007 Energy Independence and Security Act that requires new and renovated federal buildings to end their consumption of fossil fuel generated energy by 2030 and replaces Section 433 with provisions requiring federal buildings to become more energy efficient.
S. 2262: Energy Savings and Industrial Competitiveness Act of 2014
Provisions dealing with energy savings in residential, commercial and federal buildings. Language to permit manufacture of large capacity electric resistance water heaters for demand response programs.
Issues related to security and resilience of the grid.
Issues related to permitting/utility access to federal electricity rights-of-way for vegetation management and routine maintenance.
Issues related to Clean Water Act Enforcement.
Issues related to Department of Energy fossil energy funding.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Kirk |
Johnson |
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John |
Cassady |
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Brian |
Cavey |
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Christine |
Heggem |
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Montee |
Wynn |
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Julie |
Barkemeyer |
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Carol |
Whitman |
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Tammy |
Embrey |
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Bridgette |
Bourge |
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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
H.R. 935: The Reducing Regulatory Burdens Act of 2013
Preventing duplicative regulation of pesticide application.
Issues related to the following ESA legislation:
H.R. 1314, S. 19: To amend the Endangered Species Act of 1973 to establish a procedure for approval of certain settlements.
H.R. 4315: 21st Century Endangered Species Transparency Act
H.R. 4316: Endangered Species Recovery Transparency Act
H.R. 4317: State Tribal and Local Species Transparency and Recovery Act
H.R. 4318: Endangered Species Litigation and Reasonableness Act
H.R. 4319: The Common Sense in Species Protection Act
S. 2084: The Community Protection Act
H.R. 2218: Coal Residuals Reuse and Management Act of 2013
Issues related to coal combustion residuals regulation.
Issues related to Endangered Species Act Listings Lesser Prairie-Chicken, Sage Grouse and Northern Long-Eared Bat for DOI/Fish & Wildlife Service
Issues related to NMFS/USFWS proposed rulemaking on critical habitat designation.
Issues related to permitting/utility access to federal electricity rights of way for vegetation management and routine maintenance.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Kirk |
Johnson |
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John |
Cassady |
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Christine |
Heggem |
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Montee |
Wynn |
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Julie |
Barkemeyer |
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Carol |
Whitman |
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Tammy |
Embrey |
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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 FOR
16. Specific lobbying issues
H.R. 2548: Electrify Africa Act of 2014
Setting guiding policy language for U.S. investment in bringing access to electricity in Africa.
S. 2508: Energize Africa Act of 2014
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Kirk |
Johnson |
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Brian |
Cavey |
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Abbie |
Laugtug |
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Julie |
Barkemeyer |
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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 HCR
16. Specific lobbying issues
H.R. 1248: Family Health Care Flexibility Act
Repealing limits on flexible spending accounts.
H.R. 3462, S.1735: Self-Insurance Protection Act (stop-loss insurance issues)
Only 2 sections short title, and three sentences on stop-loss insurance issues.
S. 24: Small Business Health Relief Act of 2013
Repealing limits on flexible spending accounts.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Kirk |
Johnson |
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Brian |
Cavey |
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Chris |
Stephen |
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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 HOM
16. Specific lobbying issues
H.R. 3696, S. 2519: National Cybersecurity and Critical Infrastructure Protection Act of 2014
S. 2588: Cybersecurity Information Sharing Act of 2014
Provisions allowing DHS to coordinate voluntary cyber standards and information sharing; provisions amending SAFETY ACT. Issues related to sharing of security information including roles, authorities, protections and responsibilities.
H.R. 3410: CIPA; H.R. 4298, S. 2158: GRID Act
Issues related to the physical and cyber security of the electric grid.
Issues related to critical infrastructure protection, including information sharing and public private partnerships.
Issues related to cooperatives access and applications for Federal Emergency Management Disaster Relief funds.
Issues related to electromagnetic pulses and geomagnetic disturbances.
Issues related to Department of Homeland Security programs and resources available to or beneficial for critical infrastructures.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Kirk |
Johnson |
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Bridgette |
Bourge |
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Brian |
Cavey |
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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 LAW
16. Specific lobbying issues
H.R. 867, S. 394: Metal Theft Prevention Act
Provisions increasing penalties for theft of copper.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Brian |
Cavey |
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Tammy |
Embrey |
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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 RET
16. Specific lobbying issues
H.R. 5021: Highway and Transportation Funding Act of 2014
Amendments related to pension issues, normal retirement age.
Draft bills on pension reform rules for multiple-employer pension plans, definitions for normal retirement age, and not-for-profit tax treatment provisions.
Amendments to Preserving Americas Transit and Highways (PATH) Act related to pension issues, normal retirement age.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Kirk |
Johnson |
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Brian |
Cavey |
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Chris |
Stephen |
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Paul |
Gutierrez |
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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 RRR
16. Specific lobbying issues
S. 638: Railroad Antitrust Enforcement Act of 2013
Subjecting the railroads to DOJ Anti-Trust oversight.
S. 2777: Surface Transportation Board Reauthorization Act of 2014
Issues related to improving the performance of Americas Rail System.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Kirk |
Johnson |
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Brian |
Cavey |
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Christine |
Heggem |
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Paul |
Gutierrez |
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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 SMB
16. Specific lobbying issues
H.R. 2542: The Regulatory Flexibility Improvements Act of 2013
To ensure treatment of co-ops as small businesses for regulatory purposes.
H.R. 2804: Achieving Less Excess in Regulation and Requiring Transparency Act of 2014 (ALERRT Act).
To ensure treatment of co-ops as small businesses for regulatory purposes.
Issues related to the Administrations rulemaking on Waters of the U.S and its effects on small business.
Issues related to the Clean Air Act enforcement relating to the GHG regulations and their effects on small business.
Issues related to rural broadband deployment and the Connect America Fund.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Kirk |
Johnson |
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Brian |
Cavey |
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Tammy |
Embrey |
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John |
Cassady |
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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 TAX
16. Specific lobbying issues
H.R. 83: Consolidated and Further Continuing Appropriations Act, 2015
Clarification of normal retirement age (Division O, Sec. 2).
H.R. 5792: To establish a special rule for determining normal retirement age for certain existing defined benefit plans.
H.R. 5771: Tax Increase Prevention Act of 2014
S. 1270: The SAFE Retirement Act of 2013 Title II
Issues concerning retirement savings policy.
Issues related to the Tax Reform Act of 2014 (Camp Draft), tax treatment of pension plans.
Draft bills on tax reform relating to health care and retirement benefits and taxation of 501(c) organizations.
Amendments to Preserving Americas Transit and Highways (PATH) Act related to pension issues, normal retirement age.
Issues affecting Americas Energy Tax Code.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Kirk |
Johnson |
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Brian |
Cavey |
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Chris |
Stephen |
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Paul |
Gutierrez |
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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 TEC
16. Specific lobbying issues
Issues related to rural broadband deployment and the Connect America Fund.
Issues related to Pole Attachments and Broadband Telecommunications Policy.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Tammy |
Embrey |
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Brian |
Cavey |
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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 UTI
16. Specific lobbying issues
H.R. 1944: Private Property Rights Protection Act of 2013
To protect existing co-op access to Eminent Domain provisions.
Issues related to permitting/utility access to federal electricity rights of way for vegetation management and routine maintenance.
Issues related to Transmission Right-of-Way on Fort Wingate, NM.
Provisions to ensure fair and equitable treatment of electric cooperatives during the Columbia River Treaty review process.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Kirk |
Johnson |
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John |
Cassady |
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Brian |
Cavey |
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Christine |
Heggem |
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Chris |
Stephen |
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Montee |
Wynn |
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Julie |
Barkemeyer |
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Paul |
Gutierrez |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
Information Update Page - Complete ONLY where registration information has changed.
20. Client new address
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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
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ISSUE UPDATE
24. General lobbying issue that no longer pertains
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AFFILIATED ORGANIZATIONS
25. Add the following affiliated organization(s)
Internet Address:
Name | Address |
Principal Place of Business (city and state or country) |
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26. Name of each previously reported organization that is no longer affiliated with the registrant or client
1 | 3 | 5 |
2 | 4 | 6 |
FOREIGN ENTITIES
27. Add the following foreign entities:
Name | Address |
Principal place of business (city and state or country) |
Amount of contribution for lobbying activities | Ownership percentage in client | ||||||||||
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28. Name of each previously reported foreign entity that no longer owns, or controls, or is affiliated with the registrant, client or affiliated organization
1 | 5 | 9 |
2 | 6 | 10 |
3 | 7 | 11 |
4 | 8 | 12 |