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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
| Address1 | 2451 Crystal Drive |
Address2 | Suite 1000 |
| City | Arlington |
State | VA |
Zip Code | 22202 |
Country | USA |
3. Principal place of business (if different than line 2)
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5. Senate ID# 3184-12
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6. House ID# 308500000
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| TYPE OF REPORT | 8. Year | 2023 |
Q1 (1/1 - 3/31) | Q2 (4/1 - 6/30) | Q3 (7/1 - 9/30) | Q4 (10/1 - 12/31) |
9. Check if this filing amends a previously filed version of this report
| 10. Check if this is a Termination Report | Termination Date |
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11. No Lobbying Issue Activity |
| INCOME OR EXPENSES - YOU MUST complete either Line 12 or Line 13 | |||||||||
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| 12. Lobbying | 13. Organizations | ||||||||
| INCOME relating to lobbying activities for this reporting period was: | EXPENSE relating to lobbying activities for this reporting period were: | ||||||||
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| Provide a good faith estimate, rounded to the nearest $10,000, of all lobbying related income for the client (including all payments to the registrant by any other entity for lobbying activities on behalf of the client). | 14. REPORTING Check box to indicate expense accounting method. See instructions for description of options. | ||||||||
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Method A.
Reporting amounts using LDA definitions only
Method B. Reporting amounts under section 6033(b)(8) of the Internal Revenue Code Method C. Reporting amounts under section 162(e) of the Internal Revenue Code |
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| Signature | Digitally Signed By: Desmarie M. Waterhouse |
Date | 7/20/2023 7:10:04 PM |
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code UTI
16. Specific lobbying issues
Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy (DOE) as the electric sectors SMRA.
Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based.
Discussed how strong industry-government partnerships should be supported to prevent, prepare for, and respond to cybersecurity attacks.
Discussed how the federal government should play a greater role in helping electric utilities in assessing vendor cybersecurity practices, such as establishing a federal vendor certification or accreditation program.
Discussed how Congress should refrain from imposing additional cyber incident reporting mandates until the Cybersecurity Incident Reporting for Critical Infrastructure Act (CIRCIA) is fully implemented.
Provided feedback on H.R. 1160, the Critical Electric Infrastructure Cybersecurity Incident Reporting Act (all provisions).
Discussed draft legislation to direct state public utility commissions to establish cybersecurity baselines for distribution utilities (no bill number).
Discussed efforts by DOE and other stakeholders on cybersecurity baselines for distribution utilities.
Discussed funding opportunities under the Rural and Municipal Utility Advanced Cybersecurity Grant Program.
Discussed potential problems with the implementation of the Rural and Municipal Utility Grant Program at DOE (Sec. 40124(d)(1)(A) of the Infrastructure Investment and Jobs Act) regarding the provision of technical assistance.
Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment.
Discussed efforts at DOE to address the distribution transformer supply chain crisis, including President Bidens declaration to use the Defense Production Act.
Discussed concerns with the DOEs proposed energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they would worsen the distribution transformer supply chain crisis.
Discussed need for increased domestic manufacturing of equipment for electric utilities.
Discussed H.R. 763, the Supply CHAINS Act, and if the legislation could help address the distribution transformer supply chain issue.
Discussed draft legislation, the Protecting Americas Distribution Transformer Supply Chain Act, to prevent DOE from proposing or enacting new energy efficiency standards for distribution transformers for five years.
Discussed public power utility access to additional funding for loans for renewable energy created under the Inflation Reduction Act (Pub. Law 117-169), section 22001.
Discussed concerns with the DOEs draft guidance to implement section 247 (Maintaining and Enhancing Hydroelectric Incentives) in the Infrastructure Investment and Jobs Act (IIJA)(P.L. 117-58).
Discussed, S. 1521, the Community and Hydropower Improvement, and provisions giving tribes mandatory conditioning authority.
Discussed the importance of hydropower to rural public power communities.
Provided feedback on unintroduced, updated version of legislation from the 117th Congress, the BIG WIRES Act, to give the Federal Energy Regulatory Commission (FERC) the authority to require the expansion of transmission facilities for reliability, among other things (all provisions).
Discussed support for permitting reform to help expedite the construction of energy infrastructure (no bill), including changes to the National Environmental Policy Act and changes to the Federal Power Act to expedite the construction of transmission while not saddling public power utilities with transmission costs for which they receive no benefit.
Provided feedback on draft legislation, the Clean Electricity Transmission Acceleration Act (all provisions), to direct FERC to determine the existing electricity transfer capacity between regions and to establish minimum levels of transfer capabilities between each region, and to require each transmission planning region to coordinate with its neighbors to plan for the required interregional transmission.
Provided feedback on draft permitting reform legislation, the Building American Energy Security Act of 2023 (provisions on transmission).
Provided feedback on draft legislation, the CHARGE Act, to promote transmission (all provisions).
Discussed concerns with overly broad definitions of the benefits of transmission that would result in utilities and their customers paying for transmission projects from which they derive no benefit. Also discussed the importance of keeping costs affordable for customers.
Discussed the importance of keeping rates affordable as new transmission infrastructure is developed.
Discussed the importance of joint ownership opportunities for public power utilities as new transmission projects are being built.
Discussed the importance of containing costs for customers for building new transmission to accommodate a changing resource mix and to promote reliability and resilience.
Discussed concerns with language to set minimum interregional transfer capability between regions being included transmission legislation (no specific bill).
Discussed the importance of permitting reform to help build clean energy infrastructure, which will reduce greenhouse gas emissions.
Discussed public power programs to promote demand response.
Discussed the domestic content requirements in the Inflation Reduction Act (IRA) and Build America requirements in the IIJA, specifically the unique rules that apply to public power and the co-ops.
Discussed ensuring the U.S. has adequate natural gas pipeline infrastructure needed for electric reliability.
Discussed the public power business model.
Discussed how public power utilities are deploying electric vehicle charging infrastructure in their communities.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Energy - Dept of, Treasury - Dept of, Executive Office of the President (EOP), Agriculture - Dept of (USDA)
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Desmarie |
Waterhouse |
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Amy |
Thomas |
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Corry |
Marshall |
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Sarah |
Mathias |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code TAX
16. Specific lobbying issues
Discussed the importance of elective pay refundable energy tax credits for public power investments in clean energy technologies to address climate change.
Discussed the implementation of the refundable direct pay tax credit provisions included in the Inflation Reduction Act (P.L. 117-169), including the requirement to meet domestic content rules and the timing of refundable elective pay tax credit elections and returns.
Discussed section 242 of H.R. 2811, the Limit, Save, Grow Act of 2023, that would repeal the taxpayer election of payments, in lieu of credits, for specified energy property and production of electricity from certain renewable resources.
Discussed the domestic content requirements for elective payment of energy tax credits for Internal Revenue Code section 45 production tax credit (PTC), section 45Y clean electricity PTC, section 48 investment tax credit (ITC), and section 48E clean electricity ITC; and energy community bonus credits created under the Inflation Reduction Act (P.L. 117-169).
Discussed the domestic content requirements for Internal Revenue Code (IRC) section 45V(c)(2) definition of clean hydrogen and IRC section 6417 elective payment of energy tax credits (entire provision) created under the Inflation Reduction Act (P.L. 117-169).
Discussed the domestic content requirements in the Inflation Reduction Act (IRA) and Build America requirements in the Infrastructure Investment and Job Act, specifically the unique rules that apply to public power and electric cooperatives.
Discussed provisions in H.R. 3938, the Build It in America Act, to repeal of clean energy production credit (section 301) and to repeal of clean electricity investment credit (section 302).
Discussed the need to restore advance refunding bonds and support for legislation in 117th Congress, the Investing in Our Communities Act (all provisions).
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, Treasury - Dept of, U.S. SENATE, Executive Office of the President (EOP), Energy - Dept of
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
John |
Godfrey |
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Amy |
Thomas |
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Sarah |
Mathias |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code TEC
16. Specific lobbying issues
Discussed the exemption in section 224 of the Communications Act that precludes Federal Communications Commission regulation of public power pole attachments. Expressed opposition to any attempt to repeal or weaken the exemption. Discussed concerns with electric customers being forced to subsidize for-profit communications companies.
Provided feedback on draft legislation, the FAIR Poles Act (all provisions), to link receipt of broadband funding under the Infrastructure Investment and Jobs Act (P.L. 117-58) to fixed federal pole attachment rates.
Discussed support for H.R. 2552, the Community Broadband Act of 2023, to enable public power utilities to provide or assist in providing broadband services.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Corry |
Marshall |
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Desmarie |
Waterhouse |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code NAT
16. Specific lobbying issues
Discussed action by the Army Corps of Engineers on storage reallocations at hydropower dams that would reduce hydropower output.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Amy |
Thomas |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code CAW
16. Specific lobbying issues
Discussed the need for an extension of time for filing comments with the Environmental Protection Agency (EPA) on its proposed rules to regulate greenhouse gas emissions from power plants. (EPA-HQ-OAR-2023-0072)
Discussed how EPAs proposed rule to regulate greenhouse gas emissions from existing power plants would impact existing coal-fired units that are determined as must-run for electric reliability.
Discussed the rationale provided by EPA in its proposed rules to regulate greenhouse gas emissions from power plants that carbon capture, utilization, and storage and hydrogen co-firing could be achievable given long lead times for such technologies and permitting hurdles.
Discussed EPA's responsibilities under the Small Business Regulatory Flexibility Act responsibilities for regulations that impact small utilities. Expressed the need for EPA to convene Small Business Advocacy Review Panel with small utilities on its proposed rules to regulate greenhouse gas emissions from power plants.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Sarah |
Mathias |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code TRA
16. Specific lobbying issues
Discussed S. 307, the Increasing Competitiveness for American Drones Act of 2023. Discussed support for allowing drones to be used beyond visual-line-of-site for inspections and damage assessments of electric infrastructure.
Discussed language on counter-unmanned aerials system authorities previously included in S. 4687, Safeguarding the Homeland from the Threats Posed by Unmanned Aircraft Systems Act of 2022, from the 117th Congress, and the impacts for electric utility usage.
Discussed how public power utilities are deploying electric vehicle charging infrastructure in their communities.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Sarah |
Mathias |
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Corry |
Marshall |
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Amy |
Thomas |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code DIS
16. Specific lobbying issues
Discussed support for H.R. 2672/S. 1180, the FEMA Loan Interest Payment Relief Act (all provisions).
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
John |
Godfrey |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
Information Update Page - Complete ONLY where registration information has changed.
20. Client new address
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21. Client new principal place of business (if different than line 20)
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22. New General description of client’s business or activities
LOBBYIST UPDATE
23. Name of each previously reported individual who is no longer expected to act as a lobbyist for the client
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ISSUE UPDATE
24. General lobbying issue that no longer pertains
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AFFILIATED ORGANIZATIONS
25. Add the following affiliated organization(s)
Internet Address:
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Principal Place of Business (city and state or country) |
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26. Name of each previously reported organization that is no longer affiliated with the registrant or client
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FOREIGN ENTITIES
27. Add the following foreign entities:
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Principal place of business (city and state or country) |
Amount of contribution for lobbying activities | Ownership percentage in client | ||||||||||
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28. Name of each previously reported foreign entity that no longer owns, or controls, or is affiliated with the registrant, client or affiliated organization
| 1 | 3 | 5 |
| 2 | 4 | 6 |
CONVICTIONS DISCLOSURE
29. Have any of the lobbyists listed on this report been convicted in a Federal or State Court of an offense involving bribery,
extortion, embezzlement, an illegal kickback, tax evasion, fraud, a conflict of interest, making a false statement, perjury, or money laundering?
| Lobbyist Name | Description of Offense(s) |