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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 | 04/20/2014 |
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.R. 634: Business Risk Mitigation and Price Stabilization Act of 2013
Clarifies the end-user exemption from margin requirement.
H.R. 1038: The Public Power Risk Management Act, a bill to provide equal treatment for public power providers using utility operation-related swaps.
H.R. 2136: Small Business Credit Availability Act
Provides certain exemptions for small lenders.
H.R. 2642, P.L. 113-79: Federal Agriculture Reform and Risk Management Act of 2013
Issues to make improvements to RUS Electric Loan Programs.
H.R. 3547, P.L. 113-76: 2014 Consolidated Appropriations Act
Issues related to RUS Appropriations. Maintain funding for USAID Cooperative Development Program (CDP) in State and Foreign Ops bill.
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.
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 Draft legislation to reauthorize the Commodity Exchange Act (CEA).
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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Ashley |
Slater |
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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 BAN
16. Specific lobbying issues
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.
Issues related to Senate draft housing finance reform bill to include clarification allowing Federal Home Loan Bank (FHLB) investments in National Rural Utilities Cooperative Finance Corporation (CFC) securities.
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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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. 1872: Budget and Accounting Transparency Act of 2013
Issues impacting the RUS Electric Loan Program.
H.R. 3547, P.L. 113-76: 2014 Consolidated Appropriations Act
Issues related to RUS Appropriations. Maintain funding for USAID Cooperative Development Program (CDP) in State and Foreign Ops bill.
Maintain RUS lending at adequate levels, terms, and purposes for electric cooperatives.
Issues related to Low-Income Home Energy Assistance Program (LIHEAP) Funding in the Labor HHS Bill.
Issues related to House and Senate FY15 Energy and Water Appropriations Bill to ensure that the PMAs and the Bureau of Reclamation continue to operate within the bounds of their statutory authority.
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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Prof Staff - Maj., US House of Rep SBC |
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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. 3080, S. 601: Water resources reform legislation. Section 102 of S. 3080 which expedites the evaluation and processing of corps permits to make electric cooperatives eligible. Section 2014 of S. 601, which gives the Corps discretion to alter dam operations in a manner that could limit federal hydropower production.
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.
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 Waters of the U.S.
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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Ashley |
Slater |
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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. 1616, S. 1392, S. 2075: Energy Savings and Industrial Competitiveness Act of 2013
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.
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: 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 electric resistance water heaters for demand response\ that electric resistance water heaters exceeding 75 gallons.
H.R. 4066: To modify the efficiency standards for grid-enabled water heaters. The bill would create an energy efficiency standard, a demand response program participation requirement, and other requirements in order to allow continued manufacture of electric resistance water heaters exceeding 75 gallons.
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: All-Of-The-Above Federal Building Energy Conservation Act of 2013
The bill 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. 1199: All-Of-The-Above Federal Building Energy Conservation Act of 2013
The bill also 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. 1739: A bill to permit the manufacture of large capacity electric resistance water heaters for demand response
Issues related to the restructuring of the four federal PMAs.
Provisions to ensure fair and equitable treatment of electric cooperatives during the Columbia River Treaty review process.
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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Abbie |
Laugtug |
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Ashley |
Slater |
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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 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:
HR 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 and Sage Grouse for DOI/Fish & Wildlife Service.
Issues related to legislation to restore transparency to the Equal Access to Justice Act.
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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Abbie |
Laugtug |
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Ashley |
Slater |
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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
Provisions to ensure fair and equitable treatment of electric cooperatives during the Columbia River Treaty review process.
H.R. 2548: Electrify Africa Act of 2013
Setting guiding policy language for U.S. investment in bringing access to electricity in Africa.
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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Ashley |
Slater |
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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. 903: American Job Protection Act
Proposed amendment to include repeal of Affordable Care Acts 40% excise tax on high cost plans.
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.
H.R. 3489: To amend section 1341 of the Patient Protection and Affordable Care Act to repeal the funding mechanism for the transitional reinsurance program in the individual market, and for other purposes.
S. 24: Small Business Health Relief Act of 2013
Repealing limits on flexible spending accounts.
S. 1724: Union Tax Fairness Act of 2013 (payment of Transitional Reinsurance Fees under Affordable Care Act).
DRAFT Omnibus FY2014 Spending Measure (multiple-employer pension issues)
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: National Cybersecurity and Critical Infrastructure Protection Act of 2013
Provisions allowing DHS to coordinate voluntary cyber standards and information sharing; provisions amending SAFETY ACT.
H.R. 4298, S 2158: GRID Act
Issues related to the physical security of the electric grid.
Issues related to cooperatives access and applications for Federal Emergency Management Disaster Relief funds.
Provisions within FY2015 department of homeland security appropriations bill to enhance the DHS SAFETY ACT program.
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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Prof Staff - Maj., US House of Rep SBC |
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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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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.
Issues related to draft legislation to enforce railroad competition.
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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Julie |
Barkemeyer |
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Tammy |
Embrey |
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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 RET
16. Specific lobbying issues
H.R. 4275, S. 1302: Cooperative and Small Employer Charity Pension Flexibility Act of 2013
Issues related to pension regulations for electric cooperatives, including making Pension Protection Act Exemption permanent.
S. Con. Res. 12: A concurrent resolution expressing the sense of the Congress that our current tax incentives for retirement savings provide important benefits to Americans to help plan for a financially secure retirement.
Draft bills on pension reform rules for multiple-employer pension plans, definitions for normal retirement age, and not-for-profit tax treatment provisions.
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 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 Endangered Species Act effects on small businesses.
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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Ashley |
Slater |
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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. 8: American Taxpayer Relief Act
Tax treatment of retirement plans.
H.R. 4275, S. 1302: The Cooperative and Small Employer Charity Pension Flexibility Act of 2013
Issues related to pension regulations for electric cooperatives, including making Pension Protection Act Exemption permanent.
S. 1270: The SAFE Retirement Act of 2013 Title II
Issues concerning retirement savings policy.
Draft bills on tax reform relating to health care and retirement benefits and taxation of 5010(c) organizations.
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 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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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 the restructuring of the four federal PMAs.
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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Ashley |
Slater |
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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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21. Client new principal place of business (if different than line 20)
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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 |