Energy Regulation Filings

• Commented, jointly with EEI, EPSA, LPPC, NRECA, and TAPS, on a notice of proposed rulemaking that proposed to accept NERC’s revisions to its reliability standards for cybersecurity protections for low impact systems. November 24, 2025
• Commented on the Secretary of Energy’s Advanced Notice of Proposed Rulemaking on large load interconnections, urging FERC to (1) continue allowing relevant retail regulatory authorities to oversee the rates, terms, and conditions of retail service; and (2) ensure that existing customers do not bear increased cost or increased risk as a result of FERC-jurisdictional interconnection rules for large loads. November 21, 2025
• Requested clarification, jointly with EPSA, LPPC, NRECA, and TAPS, of a FERC order that changed the effective date of NERC’s cold weather reliability standard from January 1, 2026 to October 1, 2025 without citing to any legal authority for making the change. October 20, 2025
• Sponsored testimony by Randy Howard, General Manager of the Northern California Power Agency at FERC’s technical conference on best practices for reducing the risk of wildfire ignition from the bulk power system. October 14, 2025
• Intervened and protested, jointly with LPPC and NRECA, a petition for declaratory order filed by EDF Renewables asking FERC to exert jurisdiction over a public power transmission owner. August 8, 2025
• Requested clarification, jointly with EEI and NRECA, of FERC’s Order No. 907 that directed NERC to expand the scope of its internal network security monitoring reliability standards. July 25, 2025
• Commented, jointly with TAPS, on FERC’s proposal to retain annual and quarterly financial reporting obligations for public utilities. July 21, 2025
• Commented on FERC’s technical conference addressing resource adequacy constructs in organized markets. July 7, 2025
• Commented, jointly with APPA, LPPC, and TAPS, on FERC’s technical conference addressing supply chain cyber risk management. April 11, 2025
• Commented, jointly with LPPC, on NERC’s interregional transfer capability study. February 25, 2025
• Comments, jointly with LPPC, on FERC’s proposal to direct NERC to revise its supply chain risk management reliability standards. We urged FERC not to direct NERC to require responsible entities to validate the completeness and accuracy of information received from vendors during the procurement process. December 2, 2024
• Comments, jointly with EEI, NRECA, EPSA, and LPPC, on NERC's proposed reliability standard requiring internal network security monitoring ("INSM") on certain medium- and high-impact cyber systems. We urged FERC to adopt the reliability standard, but not to direct NERC to make further revisions to the standard. November 26, 2024
• Comments, jointly with EPSA, LPPC, and TAPS, in support of NERC's proposal to enhance its compliance monitoring and enforcement program to speed processing of low-risk compliance exceptions and to introduce a noncompliance transition period for significant new reliability standards. November 22, 2024
• Submitted a prepared written statement, on behalf of Randy Howard, for FERC's annual reliability technical conference, identifying five key risk areas for grid reliability: energy policy; grid transformation; extreme events; physical and cyber security; and gas-electric interdependence. October 16, 2024
• Comments, jointly with NRECA and LPPC, on FERC's advanced notice of proposed rulemaking (ANOPR) that proposed to require transmission owners to implement dynamic line ratings (DLRs). We urged FERC to postpone any new mandates for DLRs, and we recommended specific improvements that could be made to FERC’s proposal if it decides not to postpone. October 15, 2024
• Intervened and commented, jointly with LPPC, on a petition by Southwest Power Pool ("SPP") seeking a determination of the meaning of a tariff provision stating that public power entities are not required to comply with the tariff if doing so would violate state laws or regulations. June 20, 2024
• Requested rehearing of FERC Order No. 1920, FERC's long-term regional transmission planning and cost allocation rule, asking FERC to broaden the definition of Relevant State Entities to include any state or municipal entity responsible for electric utility regulation or siting electric transmission facilities. June 12, 2024
• Intervened and protested, jointly with NRECA and LPPC, a petition by Vote Solar asking FERC to initiate and enforcement action seeking to compel Salt River Project to sell energy to, and purchase energy from, residential solar customers on terms consistent with PURPA. February 12, 2024

• Commented, jointly with LPPC and TAPS, on NERC’s 2027 Business Plan and Budget, urging NERC to (1) prioritize affordability concerns, (2) tie spending to measurable performance, and (3) clarify how load growth will impact assessments. July 2026
• Submitted policy input to the NERC Board regarding its three-year strategic priorities. We emphasized the importance of prioritizing the highest impacts risks and avoiding duplicative investments by leveraging the work of regional entities or governmental entities. June 2, 2026.
• Submitted policy input to the NERC Board, urging NERC to (1) add “affordability” as a strategic priority, (2) use caution when adopting artificial intelligence tools, (3) continue to improve stakeholder participation. January 22, 2026
• Commented, jointly with TAPS, on final recommendations for improving NERC’s standards development process, urging NERC not to eliminate the industry balloting segment for transmission-dependent utilities. December 1, 2025
• Commented on a white paper on options for improving NERC’s standards development process, urging NERC to adopt changes that would streamline feedback processes while maintaining flexibility to address emerging risks. August 26, 2025
• Submitted policy input to the NERC Board, urging that any changes to the standards development process be made with the input and consensus of stakeholders. July 29, 2025
• Commented, jointly with LPPC and TAPS, on how NERC can improve its standards development process to more efficiently address reliability risks while maintaining the valuable role of stakeholder expertise. June 5, 2025
• Submitted policy input to the NERC Board supporting NERC’s focus on addressing gas-electric interdependencies, while keeping in mind regional differences when addressing interdependency issues. April 23, 2025
• Submitted policy input to the NERC Board, urging NERC to (1) collaborate with stakeholders to identify reliability gaps associated with large loads, and (2) ensure public power perspectives are reflected in the 2025 ERO Risk Priorities report. January 29, 2025
• Submitted policy input to the NERC Board, urging NERC to (1) explicitly consider affordability for ratepayers in its strategic planning, (2) respect its statutory limitations prohibiting standards from requiring the building or enlarging of facilities, and (3) enhance its compliance monitoring and enforcement efforts to improve flexibility for registered entities and reduce the administrative burdens associated with compliance. July 24, 2024
• Submitted policy input to the NERC Board, focused on the importance of meaningful stakeholder participation in NERC governance (i.e., more interaction between the Board and the Members Representatives Committee, respect for the industry-led standard drafting process, and stronger collaboration between NERC staff and the trade associations). May 2, 2024
• Submitted policy input to the NERC Board, focused on improving stakeholder engagement, improving the efficiency of standards development, and improving NERC's communications. February 5, 2024

Other

• Commented, jointly with EEI, LPPC, and NRECA, on the Federal Aviation Administration’s proposed rule for establishing drone flight restrictions over critical infrastructure. We support the effort, but told the FAA that its proposal would leave most of the grid unprotected, impose undue burdens on electric utilities seeking flight restrictions, and constrain utilities’ ability to use their own drones for maintenance and inspection. August 5, 2026
• Submitted supplemental comments, jointly with EEI, LPPC, and NRECA, on the Federal Communication Commission notice on Unleashing American Drone Dominance. We continued to urge the FCC to enable scalable unmanned aircraft systems (UAS) deployment while protecting critical infrastructure and aviation safety. May 28, 2026.
• Commented, jointly with EEI, LPPC, and NRECA, on the Federal Communication Commission notice on Unleashing American Drone Dominance. We urged the FCC to prioritize policies that enable utilities to deploy unmanned aircraft systems (UAS) safely and at scale through appropriate spectrum access and regulatory certainty. May 1, 2026
• Commented, jointly with EEI, LPPC, and NRECA, on the Federal Aviation Administration’s supplemental request for information regarding unmanned aircraft systems beyond visual line of sight operations.  We urged the FAA to ensure safety and avoid collisions by adopting technology requirements that allow cooperative detectability where every aircraft can detect and be detected. February 11, 2026
• Commented on the Department of Energy’s Speed to Power Initiative. We described the important role that public power utilities play in serving new artificial intelligence data centers, and identified barriers that constrain the ability of public power utilities to expand their capacity to serve new loads while protecting their existing customers from undue costs and risks. November 21, 2025
• Commented, jointly with EEI, LPPC, and NRECA, on the Federal Aviation Administration’s proposed rule to normalize unmanned aircraft systems beyond visual line of sight operations.  We supported the FAA’s efforts to facilitate grater drone usage, and urged specific improvements to the rule that would tailor the rule for the electric utility sector because of our industry’s distinctive characteristics and central role in supporting the nation’s economy and security. October 6, 2025

CISA

• Comments on CISA’s proposed rule to implement the requirements of the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA). We urged CISA to exclude small, distribution-only electric utilities from the reporting obligation and to harmonize its reporting obligations with other federal reporting requirements before finalizing the rule. July 3, 2024