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 potential legislation regarding the Energy Threat Analysis Center and obstacles to increased public power participation.

Discussed support for the reauthorization of the Cybersecurity and Information Security Act of 2015 (passed as Division N of P.L. 114-113) and provisions to maintain public power utilities inclusion in the definition of private entity in section 102(15)(B) and maintaining public power utilities inclusion in section 104(B) - Exemption from Disclosure.

Discussed the urgent need for a replacement for the public disclosure exemptions that were provided under the Critical Infrastructure Partnership Advisory Council to facilitate information sharing at Electricity Subsector Coordinating Council meetings (no legislation).

Discussed CISAs work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates.

Discussed support for S. 1337, the Cybersecurity Information Sharing Extension Act (all provisions).

Discussed support for H.R. 5079, the Widespread Information Management for the Welfare of Infrastructure and Government Act (all provisions).

Discussed concerns with the creation of additional cyber incident reporting requirements for electric utilities (no legislation).

Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions).

Discussed support of H.R. 3657, the Hydropower Licensing Transparency Act, to direct the Federal Energy Regulatory Commission (FERC) to report annually to Congress on the status of the relicensing process for each application for a renewed hydropower dam license.

Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions).

Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation).

Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, from the 118th Congress, which would have expanded the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would have exempted Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation.

Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation).

Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes.

Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes.

Discussed grid-enhancing technologies (GETS) and interconnection queue reform. Also discussed the need to ensure savings related to GETS benefits public power utilities and their customers (no bill).

Discussed support for H.R. 3616, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions).

Provided feedback on a draft bill to create a new must consider provision under section 111(d) of the Public Utility Regulatory Policy Act that would seek to create interconnection procedures to support microgrids.

Discussed public powers concerns about transmission affordability, including transmission incentives.

Discussed FERCs concerns about resource adequacy and the results of recent capacity auctions, including issues in Docket AD25-7.

Discussed the importance of reliability, including coordination between the gas and electricity sectors.

Discussed the North American Electric Reliability Corporations (NERC) electric reliability standards development procedures and the impact of FERC Order No. 907 (directing modifications to NERCs critical infrastructure protection standards) on the prioritization of NERCs standards development work.

Discussed the importance of the Tennessee Valley Authority in providing affordable and reliable power to the Tennessee Valley.

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

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

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 opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds.

Discussed opposition to potential budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 to amend, in whole or in part, 26 USC 6817, elective payment of energy tax credits.

Discussed support for possible legislation to amend 26 USC 6417, elective payment of energy tax credits.

Discussed opposition to possible guidance superseding IRS Notice 2013-29, defining beginning of construction for purposes of designating a qualifying facility for certain clean energy projects.

Discussed support of possible guidance relating to 26 USC 45U, existing nuclear tax credit, and 26 USC 7701(51)(a), prohibited foreign entity debt test.

Discussed the need for the Treasury Department to issue 45U tax guidance for existing nuclear tax credits (no legislation).

Discussed possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts.

Discussed support for possible regulations to implement section 26 USC 7701(a)(51), prohibited foreign entity debt test.

Discussed support for possible regulations to 26 USC 6417, elective payment of energy tax credits.

Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions).

Discussed support for possible legislation to waiver 2 USC 20A, Statutory Pay-as-You-Go, in relation to the budget effects of P.L. 119-21, the One Big, Beautiful Bill Act of 2025.

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

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

16. Specific lobbying issues

Discussed the importance of maintaining adequate staffing levels at the Power Marketing Administrations (no legislation).

Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund.

Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam.

Discussed support for H.R. 1001, to provide for a memorandum of understanding to address the impacts of a certain record of decision on the Upper Colorado River Basin Fund.

Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation).

Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands.

Discussed draft legislation to amend the Forest Land Policy and Management Act (P.L. 94-579) to amend strict liability caps for wildfires on federal lands.

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

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 increased funding for the Low Income Home Energy Assistance Program (no legislation).

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 (all provisions) to provide financial assistance to a local government or electric cooperative as reimbursement for interest paid on a loan used for emergency or disaster recovery activities later paid for by FEMA assistance. Discussed support for its reintroduction in the 119th Congress.

Discussed support for H.R. 2836, the FEMA Loan Interest Payment Relief Act (all provisions) to provide financial assistance to a local government or electric cooperative as reimbursement for interest paid on a loan used for emergency or disaster recovery activities later paid for by FEMA assistance.

Discussed the need for FEMA reform (no legislation).

Provided feedback on draft legislation, the Fixing Emergency Management for Americans (FEMA) Act, including section 101, to replace existing section 406 cost-based grants with new Stafford Act section 409 estimate-based grants and section 301, expanding preapproved hazard mitigation lists to include public power. Also discussed section 117 on expedited funding for emergency work, section 118 to clarify the definition of local in constancy in procurement practices, and section 122 on loan interest payment relief.

Discussed support for H.R. 4669, the FEMA Act (all provisions), including section 101 on rebuilding public infrastructure.

Provided feedback on draft legislation to reform the Stafford Act to allow for better grid technology when rebuilding downed power lines after a disaster.

Discussed the termination of the Building Resilient Infrastructure and Communities program at FEMA, which provides funding to support eligible entities undertaking pre-disaster and hazard mitigation projects or capability and capacity building activities to reduce their risks from disasters and natural hazards.

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 ENV

16. Specific lobbying issues

Discussed the Environmental Protection Agencys (EPA) efforts to review the legacy coal combustion residuals rulemakings, including compliance extension deadlines for coal combustion residual management units, as well as potential updates to the legacy rule risk assessment and support for state CCR permit programs (Docket No. EPA-HQ-OLEM-2020-0107).

Discussed H.R. 4875, the Coal Ash for American Infrastructure Act (all provisions).

Discussed the need for the development of a federal coal combustion residuals (CCR) permitting program, the timely review and approval of state CCR programs by EPA, and support for the beneficial reuse of CCRs.

Discussed the need for EPA to develop a CCR program that allows for site-specific, risk-based considerations and promotes the beneficial use of CCRs (no legislation).

Discussed support for H.R. 4776, the SPEED Act, to reform permitting processes under NEPA (all provisions).

Discussed support for H.R. 4503, the ePermit Act, to digitize the federal permitting process for environmental reviews.

Discussed support for H.R. 573, Studying NEPAs Impact on Projects Act, to direct the Council on Environmental Quality (CEQ) to annually report on the impact of NEPA on projects that require NEPA review. CEQ must publish the report on its website and submit it to certain congressional committees.

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

Environmental Protection Agency (EPA), 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 COM

16. Specific lobbying issues

Discussed opposition to H.R. 278, BROADBAND Leadership Act, to effectively gut the exemption in section 224 of the Communications Act of 1934, which prevents the Federal Communications Commission from regulating public power pole attachments.

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 CAW

16. Specific lobbying issues

Discussed general support for the repeal of the 2024 Carbon Pollution Standard (Docket No. EPA-HQ-OAR-2025-0124). Discussed the potential reliability impacts from the rule, as well impracticality of using carbon capture and storage technology to reduce emissions given the current state of the technology.

Discussed concerns with the 2024 Effluent Limitation Guidelines Rule and the costs of various wastewater treatment technologies required to comply with the rule (Docket No. EPA-HQ-OW-2009-0819). Discussed the administrations plans to reconsider the rule and the challenges with meeting the compliance deadlines in the 2024 rule.

Discussed support for H.R. 3898, the PERMIT Act, to improve the permitting process for infrastructure projects under the Clean Water Act. Discussed the provision regarding nationwide permitting and the determination of the appropriate acreage threshold for discharges into Waters of the US (WOTUS) and the provision regarding the section 18 statutory exclusion from the regulatory definition of WOTUS for waste treatment systems. Also discussed section 6, clarifying federal general permits and section 15 judicial review timelines clarity.

Discussed H.R. 1267, the Water System PFAS Liability Protection Act, and the need for PFAS liability protection for electric utilities in addition to public water systems.

Discussed S. Amdt. 3363 to S. 2296, the National Defense Authorization Act for Fiscal Year 2026, which would provide PFAS liability protection to public water systems and the need to include public power.

Discussed support for H.R. 161, the New Source Review Permitting Improvement Act (all provisions).

Discussed the need to define the term relatively permanent rather than leaving it open to interpretation. Also discussed the definition of continuous surface connection and the exclusion for waste treatment systems under the Waters of the U.S. definition. (Final Clarifying Definition of Waters of the United States, RIN 2040-AG44).

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

U.S. HOUSE OF REPRESENTATIVES, Environmental Protection Agency (EPA), U.S. SENATE, Office of Management & Budget (OMB)

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 the potential impact of siting nuclear power plants, such as small modular reactors, at Department of Defense facilities currently served by local electric utilities (no legislation). Discussed the potential for policy proposals to result in the stranding of existing utility assets and the imposition of new regulatory burdens on the Department of Defense.

Discussed the importance of nuclear power (no legislation).

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