Energy Regulation Filings

• 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

• 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

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