Policy Positions

Issue Briefs

The American Public Power Association’s policy positions are reflected in the issue briefs listed below on various topics as well as in resolutions approved annually by members. The Association also acts on members’ behalf through regulatory comments and filings with various federal administrative agencies as well as in the courts.

Build America Bond Sequestration [PDF] Distributed Energy Resources [PDF] Drones for Utility Operations [PDF]
Electric Vehicles [PDF] Energy Efficiency [PDF] Federal Efforts to Address Climate Change [PDF]
Federal Power Program [PDF] Grid Resilience [PDF] Grid Security [PDF]
Hydropower [PDF] Municipal Bonds [PDF] Nuclear Power [PDF]
Pole Attachment Regulations [PDF] Public Utility Regulatory Policies Act of 1978 [PDF] Rail Competition and Antitrust Enforcement [PDF]
RTO Capacity Markets [PDF] Stafford Act Reform [PDF] Transmission Policies [PDF]
Waters of the United States [PDF] Wholesale Electricity Markets [PDF]  


Fact Sheets

Electricity Generation [PDF]  


Regulatory Filings

The Association acts on members’ behalf through regulatory comments and filings with various federal administrative agencies and in the courts — the most important of which are listed below.

Participation of DER Aggregations in RTO and ISO Markets
Comments filed with FERC, 6-26-18

GHG Emission Guidelines for Existing Stationary Sources
Comments filed on ANPRM with EPA, 2-26-18

NERC Supply Chain Risk Management Reliability Standards
Comments filed with FERC, 3-26-18
Tax Cuts and Jobs Act Notice of Inquiry
Comments filed with FERC, 5-21-18
Electric Storage Participation in Markets Operated by RTOs and ISOs
Request for rehearing filed with FERC, 3-19-18
De Minimis Exception to the Swap Dealer Definition 
Comments filed with CFTC, 8-13-18
Proposed Affordable Clean Energy Rule
Comments filed with EPA, 10-31-18
Discharges of Pollutants via a Direct Hydrological Connection
Comments filed with EPA, 5-21-18



The Association’s policy positions are reflected in the resolutions approved by the membership in 2019. Resolutions are proposed annually by interested members, adopted by the Legislative & Resolutions Committee, and voted on by all members at the annual Association Business Meeting.

19-01: In Support of Reducing Wildfire Risk by Adequately Funding Fire Suppression and Forest Health Programs 19-04: In Support of Municipal Bond Modernization
19-02: In Support of Ensuring Proper Cost Allocation for the Central Valley Project Improvement Act 19-05: In Support of Controlling Transmission Cost Increases
19-03: In Support of Affirming Local Control of Pole Attachments  19-06: In Support of Strengthening Protections Against Fraudulent Communications While Ensuring Public Power Utilities Can Communicate with Customers for Service Related-Issues