Advocating For
‍Public Power

ENHANCE GRID RESILIENCE, SECURITY, AND RECOVERY

Support for Partnerships That Allow the Grid to Withstand and Rapidly Recover from System Disruptions

The electric industry, government, and academia should continue to work together to enhance the ability of the electric grid to adapt to changing conditions and to withstand and rapidly recover from system disruptions, including:

• Enhancing cyber and physical security. LPPC supports federal efforts to protect against cyber and physical security threats by encouraging alignment with a risk-based security framework and by building upon existing regulations and voluntary programs, with a focus on changing threats, technologies, sharing of best practices, and timely intelligence.
• Supporting supply chain capacity and security. LPPC supports federal efforts to evaluate supply chain vulnerabilities and capacity constraints and actions that could spur domestic production for key components and equipment. LPPC members believe the energy supply chain should be secured from a cyber and sourcing perspective in the most efficient way, with suppliers subject to reasonable regulation enforced by the federal government rather than duplicative and ineffectual efforts applied at each individual utility.
• Enhancing federal resiliency investment. LPPC advocates for additional federal investment to enhance the ability of the grid to withstand disruptions and extreme natural events, while maintaining affordability for customers.
• Reducing unnecessary complexity and recognizing the value of pre-staging for disaster recovery. LPPC advocates for the Federal Emergency Management Agency (FEMA) to reduce unnecessary complexity so as to allow public power utilities to obtain timely reimbursement for disaster recovery. LPPC also advocates for FEMA to reimburse an electric utility’s reasonable costs to pre-stage service restoration supplies and crews needed to shorten anticipated weather-caused service disruptions. Electric utilities are first responders providing an essential public service and undertake enormous expenses to prepare for events and restore electric service.

Reducing Wildfire Risk. LPPC supports improvements to current law to allow public power entities to reduce wildfire risks before disaster strikes through streamlined permitting and enhanced vegetation management.

SUPPORT RESPONSIBLE AND EFFECTIVE FEDERAL REGULATION OF THE BULK POWER SYSTEM

Foster Collaboration Between Regulators and Industry Participants to Address Emerging Risks and Ensure a Robust, Adaptable Regulatory Framework

LPPC supports responsible and effective federal regulation that maintains the reliability, resilience, and security of the bulk power system. Regulations and reliability standards should be developed with transparent stakeholder engagement and industry feedback mechanisms, as outlined in NERC’s standards development process. Additionally, regulations and standards should be risk-based, practical, enforceable, and achievable, enabling compliance without imposing undue burdens on the industry while maintaining standards of reliability and security for the grid. To support the regulatory model established by Section 215 of the Federal Power Act, LPPC members will nominate qualified subject-matter experts to the NERC Members Representatives Committee, standing committees, subcommittees, working groups, and task forces.

ELECTRICITY MARKETS SHOULD ENCOURAGE EFFICIENCY AND RELIABILITY

Wholesale Electricity Markets Should Provide Economic Accountability and Reliability Benefits to Customers

LPPC members participate in both bilateral and organized wholesale electricity markets. Organized markets should:

• Be voluntary, transparent, resource-neutral, and designed and operated to provide net benefits to customers.
• Allow for different resource mixes based on local, state, and regional choices.
• Provide for independent governance, include public power representation within the stakeholder processes, and enable input to decision-makers.
• Base compensation on resource attributes, not resource types.

Where organized wholesale markets do not presently exist, the formation or expansion of an organized market should provide benefits to customers and preserve the local decision-making and flexibility of public power entities.

SUPPORT ENVIRONMENTAL REGULATIONS THAT PROVIDE WORKABLE, DURABLE FRAMEWORKS FOR RELIABLE, AFFORDABLE, AND CLEAN ELECTRICITY

Revisions to the EPA’s Power Plant CO2 Rule Are Needed to Achieve a Reliable, Affordable Clean Energy Transition and Meet Record Electricity Demand

LPPC members support workable, durable federal environmental policies that responsibly advance clean energy. Our utilities have some of the cleanest generation portfolios in the industry and are leaders in investing in zero- and low-carbon resources and expanding the ways that electricity is used to power our nation. LPPC’s priorities include federal policies that:

• Recognize the importance of maintaining reliability and affordability for consumers and enable flexible compliance that allows for regional resource differences.
• Are well coordinated among federal agencies and between industry and government.
• Rely on the North American Electric Reliability Corporation (NERC) to perform the necessary technical studies to ensure reliability can be maintained in the face of dramatic load growth and changes in the generation mix.
• Demonstrate and support the deployment of innovative technologies, including advanced dispatchable renewables, low-carbon fuels like hydrogen and renewable natural gas, advanced nuclear energy, carbon capture and storage, long-duration storage, advanced grid capabilities, and efficient demand side technologies.

The EPA’s Power Plant CO2 Rule was well intended but needs revisions to establish a workable, durable framework for clean energy that maintains reliability and meets growing electricity demand. In particular, LPPC’s priorities for the CO2 Rule include:

• The ability to permit the most efficient plants, without unnecessarily raising cost. Utilities seeking air permits for new natural gas plants need to either meet a 90% carbon capture standard for the unit by 2032 (which is not technically achievable), or run below a 40% capacity factor (which is costly while not reducing carbon emissions). While LPPC members are pursuing carbon capture, the technology and supply chain for deployment are nascent and cannot meet electricity needs in this timeframe. Building and operating smaller, less efficient plants to comply with the Rule is costly to customers and increases CO2 emissions.
• Recognizing supply chain challenges to meeting rapidly growing electricity demand. Lead times for new natural gas turbines extend to five years or more. The Rule exacerbates electric supply challenges by capping the run time of new natural gas plants needed for reliability, without reducing CO2 emissions. More plants are built to run less, producing similar amounts of CO2. Studies show that maintaining a sufficient supply of dispatchable natural gas generation as a backstop for intermittent generation sources is required to allow the electric sector to decarbonize while also reliably meeting the growing demand for electricity.
• Acknowledging that additional large scale coal plant retirements by 2032 challenges reliability. The Rule mandates that existing coal plants co-fire with 40-percent natural gas by 2030, retire by 2032, or install carbon capture by 2032. Plants are challenged by a lack of pipeline and storage capacity and an inability to obtain timely permits for new pipelines and storage for both natural gas and carbon capture. Carbon capture technology and the supply chain that supports it are nascent. The Rule would trigger massive additional coal plant retirements by 2032 that threaten reliability and exacerbate America’s near-term electricity supply deficit.

SUPPORT FOR COMMUNITIES THROUGH ENERGY ASSISTANCE PROGRAMS

Provide Ample Aid to Meet the Electricity Needs of Struggling Households and Small Businesses

Federal programs should ensure equitable access to energy across communities so that low-income consumers are able to pay for essential utility services. Programs such as the Low Income Home Energy Assistance Program (LIHEAP) and the Weatherization Assistance Program (WAP) are proven and effective tools to address energy insecurity and should remain a priority for federal funding.

DEVELOPING OUR ESSENTIAL ENERGY WORKFORCE

Implement Programs to Develop and Train the Energy Sector Workforce, Including Cybersecurity and Emerging Technologies

LPPC supports federal workforce development programs that enhance the pipeline of qualified and diverse employees in highly technical STEM-related fields, including cyber security and emerging technologies. The electric industry employs essential workers in highly technical fields who ensure the safety of our community and provide reliable power for essential service. Workforce development reduces the cost and delays of new projects, allows the United States to lead in emerging fields such as storage and advanced nuclear, and enhances the ability of the nation to respond to rapidly rising demand.