Letters/Comments

Using our knowledge regarding how federal actions on electricity policy can directly impact the well-being of tens of millions of America’s citizens, LPPC files comments with various agencies.

Finance & Infrastructure

June 19, 2017
LPPC Joint Letter to Rep. Ryan and Rep. Pelosi, Correcting IRC Nuclear Production Tax Credit

May 15, 2017
LPPC Letter To SEC Secretary Brent Fields On Proposed Amendments To Municipal Securities Disclosure

March 24, 2017
Joint Comments to FERC on Establishing the Length of License Terms for Hydroelectric Projects

April 8, 2016
LPPC Letter to Ranking Member Levin Urging House Ways and Means Committee to Retain Tax-Exempt Financing for State and Local Governments

April 8, 2016
LPPC Letter to Chairman Brady Urging House Ways and Means Committee to Retain Tax-Exempt Financing for State and Local Governments

April 7, 2016
LPPC Joint Trade Letter Urging Senate Finance Committee To Address Issues Associated With The Nuclear Production Tax Credit (PTC)

September 17, 2015
Joint APPA-LPPC Comments To NERC On Oversight Role Under Section 215 Of The Federal Power Act

March 11, 2015
LPPC President John Di Stasio statement to FERC Technical Conference on Environmental Regulations and Energy Reliability, Wholesale Electricity Markets and Energy Infrastructure

September 17, 2013
LPPC Letter to SEC Secretary Elizabeth Murphy Regarding the Proposed Changes to Rule 2a-7, S7-03-13 and the Importance of MMMFs

September 17, 2013
LPPC and Coalition of Municipal Issuers Letter to SEC Secretary Elizabeth Murphy Regarding the Proposed Changes to Rule 2a-7, S7-03-13 and the Importance of MMMFs

May 1, 2013
APPA LPPC Commodity Exchange Act Reauthorization Letter to Senate Agriculture Committee

December 20, 2012
LPPC Joint Letter To President Obama And Speaker Boehner Regarding The Importance Of The Income Tax-Exempt Financing To Public Infrastructure And Services

November 20, 2012
LPPC Joint Letter on EE Tax Extenders to Speaker Ryan, Democratic Leader Pelosi, Majority Leader McConnell and Democratic Leader Reid

November 19, 2012
LPPC joint letter to Chairman Gensler Regarding Relief from Special Entity de minimis Threshold Swaps Related to Government-Owned Utilities

August 1, 2012
Letter to Chairman Gensler Regarding Special Entity Sub-Threshold

Reliability & Security

June 13, 2017
Letter to Congressman Bishop Supporting H.R. 1873, Electric Reliability and Forest Protection Act

April 13, 2017
Joint APPA-LPPC Comments to FERC on Review of Generator Interconnection Agreements and Procedures 

April 11, 2017
LPPC Comments to Senate Energy and Natural Resources Subcommittee on Cyber Security Threats to U.S. Electric Grid 

March 28, 2017
Senate Cybersecurity Hearing - Di Stasio Testimony

February 17, 2017
Joint Comments to FERC on Foundation for Resilient Societies

February 6, 2017
Joint APPA, LPPC NRECA and TAPS Comments to DOE on Grid Security Emergency Orders

January 31, 2017
SM-TDU Sectory Policy Input Response to NERC Board of Trustees

December 15, 2016
Joint APPA, LPPC and NRECA Comments to FERC on Review of Generator Interconnection Agreements and Procedures 

November 28, 2016
Joint EEI, APPA and LPPC Comments to FERC on Balancing Authority Control, Inadvertent Interchange and Facility Interconnection Reliability Standards 

April 16, 2016
LPPC Joint Trade Letter To Senate Majority Leader McConnell And Senate Minority Leader Reid In Support of Energy Efficiency Provisions In The Energy Policy Modernization Act Of 2015

January 28, 2016
LPPC Letter To Senate Energy And Natural Resources Committee Leadership In Support Of Grid Reliability Provision In Comprehensive Energy Legislation

January 20, 2016
LPPC Joint Trade Letter To Majority Leader McConnell And Minority Leader Reid Expressing Support For Energy Efficiency Provisions In Energy Policy Modernization Act

November 12, 2015
LPPC Joins Industry Letter to Honorable Richard Burr, Honorable Michael McCaul, Honorable Devin Nunes, Honorable Dianne Feinstein, Honorable Bennie Thompson, and Honorable Adam Schiff Concerning Section 407 of the Cyber Security Information Sharing Act 

October 13, 2015
LPPC Joins Trade Letter To Senate Concerning Amendments To Cyber Security Information Sharing Act 

July 24, 2015
LPPC Letter To Senate Energy And Natural Resources Committee On Reliability Assurance Mechanism

July 17, 2015
LPPC Letter To House Energy And Commerce On Reliability Assurance Mechanism

June 11, 2015
LPPC Letter In Support Of Electric Reliability And Protection Act

March 24, 2015
LPPC President John Di Stasio Statement to FERC Technical Conference on Reliability Assurance Mechanism

January 27, 2015
LPPC Joins Multi-association Letter Urging Senate to Pass Cyber Security Information-sharing Legislation 

November 20, 2014
LPPC Joins Electric Utility Cyber Coalition in Letter Urging Sen. Reid and Sen. McConnell to Pass Cyber Security Information Sharing Act of 2014 

June 6, 2014
Electric Power Sector Letter to Sen. Feinstein and Sen. Chambliss on Cyber Threat Information Sharing 

December 13, 2013
Joint APPA-LPPC Comments to NIST on Preliminary Cyber Security Framework

April 9, 2013
Letter from Electric Power Sector Supporting H.R. 624, Cyber Intelligence Sharing and Protection Act CISPA

December 26, 2012
LPPC FERC Comments Docket No. RM12-22-000
UNITED STATES OF AMERICA
BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION
Reliability Standards for Geomagnetic Disturbances
Docket No. RM12-22-000

The American Public Power Association (“APPA”), the Edison Electric Institute (“EEI”), the Large Public Power Council (“LPPC”) and the National Rural Electric Cooperative Association (“NRECA”), jointly on behalf of their respective member companies (collectively the “Trade Associations”) hereby respectfully submits these Comments in response to the Notice of Proposed Rulemaking (“NOPR”) issued by the Federal Energy Regulatory Commission (“Commission” or “FERC”) on October 18, 2012, in the above-referenced docket. The NOPR proposes to direct the North American Electric Reliability Corporation (“NERC”) to create and submit Reliability Standards that address and mitigate the effects of geomagnetic disturbances (“GMDs”) on the Bulk- Power System (“BPS”) caused by solar events.

October 12, 2012
Electric Power Cyber Coalition Supports Robust Electric Grid

Environmental Stewardship

May 15, 2017
LPPC Comments On Existing Federal Environmental Regulations

November 1, 2016
LPPC Comments to the EPA on the Clean Energy Incentive Program (CEIP) 

January 27, 2016
LPPC Joint Trade Letter In Support Of Bipartisan Hydropower Provisions In Energy Policy Modernization Act

November 25, 2015
Letter in support of McKinley Coal Combustion Residuals Legislation 

March 18, 2015
Letter in support of Improving Coal Combustion Residuals Regulation Act of 2015 

December 15, 2015
LPPC Comments To The EPA On The Clean Energy Incentive Program (CEIP)

November 18, 2015
LPPC Joint Trade Letter On Hydropower To Speaker Ryan And Minority Leader Pelosi

June 21, 2013
LPPC Letter To Speaker Boehner And Leader Pelosi In Support Of H.R. 2218 The Coal Residuals Reuse And Management Act of 2013 

January 17, 2013
LPPC Letter to Congressman Pete Olson in Support of H.R. 271, the Resolving Environmental and Grid Reliability Conflicts Act of 2013

The Honorable Pete Olson
U.S. House of Representatives
312 Cannon House Office Building
Washington, DC 20515

Dear Congressman Olson:

On behalf of the Large Public Power Council (LPPC), I am writing to express our support for H.R. 271, the Resolving Environmental and Grid Reliability Conflicts Act of 2013. LPPC represents 26 of the largest locally owned and operated not-for-profit electric systems in the nation. Members are located in 11 states and Puerto Rico, and supply electricity to some of the largest cities in the country — including Los Angeles, Seattle, Omaha, Phoenix, Sacramento, Jacksonville, San Antonio, Orlando and Austin.

Collectively, our members own and operate approximately 35,000 circuit miles of transmission lines and over 86,000 megawatts of generation, reflecting a portfolio of renewable energy, fossil fuel, nuclear, hydropower and other resources.

LPPC supports H.R. 271 as an important tool to help maintain the electric grid reliability. In the narrow set of circumstances under which an electricity generation unit must run under an emergency order of the Federal Power Act, this bill would protect the unit from being in violation of environmental laws and would ensure that electricity generators are not forced to choose between conflicting legal obligations when acting to comply with an emergency reliability order from the U.S. Department of Energy. We anticipate that Emergency Orders may become more frequent as utilities take actions to comply with the new EPA regulations.

The members of the LPPC remain concerned that electric reliability could be jeopardized unless there is an effective mechanism in place to extend the utility MACT compliance deadline for those electric generating units that pose local or regional reliability problems.

Thank you for introducing this narrowly focused legislation that highlights an important issue affecting electric utilities.

If you have any questions or need additional assistance in this matter, please feel free to contact me or LPPC’s Executive Director, Missy Mandell at lppc@lppc.org or call 202-430-0101.

Sincerely,
Lonnie N. Carter
LPPC Chairman​

November 19, 2012
LPPC Letter to Senators Reid and McConnell in support of Coal Ash and Recycling Act of 2012 

May 8, 2012
LPPC Letter To Transportation Conference Committee In Support Of Coal Combustion Residual Recycling Provision 

February 29, 2012
FERC MACT Comments 

September 7, 2011
Letter To Senate Majority Leader Reid And Senate Minority Leader McConnell On Energy Efficiency Legislation