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.
March 28, 2017
Senate Cybersecurity Hearing - Di Stasio Testimony
February 17, 2017
Joint Comments to FERC on Foundation for Resilient Societies
January 31, 2017
SM-TDU Sectory Policy Input Response to NERC Board of Trustees
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
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
November 25, 2015
Letter in support of McKinley Coal Combustion Residuals Legislation
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 email@example.com or call 202-430-0101.
Lonnie N. Carter
February 29, 2012
FERC MACT Comments