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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 | 10/20/2023 10:59:47 AM |
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 physical security and cybersecurity collaboration with the federal government.
Discussed the Cyber Incident Reporting Council report released by the Cybersecurity and Infrastructure Security Agency that outlines steps the federal government should take to streamline its incident reporting regulations.
Expressed concerns with H.R. 1160, the Critical Electric Infrastructure Cybersecurity Incident Reporting Act (all provisions).
Discussed draft legislation to impose cybersecurity baseline standards on distribution utilities (no bill number).
Discussed efforts by DOE and other stakeholders on cybersecurity baselines for distribution utilities.
Discussed proposed amendments to S. 2226, the Fiscal Year 2024 National Defense Authorization Act - #312 - assessment of existing large power transformers; #249 - study on energy resilience and reliability posture of military departments; #706 - Federal Information and Security Modernization Act of 2023.
Discussed S. 914, the Energy Threat Analysis Center Establishment Act of 2023, to establish an energy threat analysis center within the Department of Energy (all provisions).
Discussed S. 934, a bill to amend the DOE Organization Act to assign certain functions to the Assistant Secretaries of Energy relating to energy emergencies and energy security, and for other purposes.
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.
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 distribution transformer standardization efforts.
Discussed efforts to gather further data on distribution transformer shortage.
Discussed draft legislation to raise energy efficiency standards for certain types of distribution transformers.
Discussed draft legislation, the DOE Appliance and Equipment Standards Reform and Consumer Protection Act.
Discussed H.R. 4167/S. 2036, the Protecting Americas Distribution Transformer Supply Chain Act, to prevent the Department of Energy from proposing or enacting new energy efficiency standards for distribution transformers for five years.
Expressed concerns with the DOE Grid Resilience and Innovation Partnerships (GRIP) program application requirements, particularly for smaller utilities with limited resources. Provided feedback on how DOE should make the process simpler, more transparent, and provide assistance and support for small and/or rural public power applicants.
Discussed public power utilities experiences with applying for Infrastructure Investment and Jobs Act (IIJA) grants, including the GRIP program.
Discussion of concerns with domestic content requirements in Infrastructure Investment and Jobs Act (Pub. Law 117-58) and how they make it too difficult for public power utilities to access the grants.
Discussed, S. 1521, the Community and Hydropower Improvement Act, and provisions giving tribes mandatory conditioning authority.
Discussed the importance of improving the hydropower licensing and relicensing process (no bill).
Discussed support for H.R. 4045, the Hydropower Clean Energy Future Act.
Discussed support for S. 2994, the Maintaining and Enhancing Hydroelectricity and River Restoration Act of 2023 (all provisions).
Discussed draft legislation, the Grid Reliability and Integrated Data Act (all provisions), which could require new and mandatory data collection from utilities, especially smaller utilities.
Discussed draft legislation, the BIG WIRES Act, to give the Federal Energy Regulatory Commission the authority to require the expansion of transmission facilities for reliability and establish thresholds for interregional transfer capability (all provisions).
Discussed opposition to efforts to reform permitting, siting, and cost allocation processes for electric transmission that significantly expand federal authority or change the beneficiary pays principle (no bill).
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.
Discussed support for provisions in H.R. 1577, the BUILDER Act of 2023, to reform the National Environmental Policy Act, that were also included in H.R. 3746, the Fiscal Responsibility Act (Pub. L. No. 118-5).
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Energy - Dept of, White House Office, Homeland Security - Dept of (DHS), Office of Management & Budget (OMB)
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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Corry |
Marshall |
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Sarah |
Mathias |
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John |
Godfrey |
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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 included in the Inflation Reduction Act (Pub. Law 117-169) for public power investments in clean energy technologies to address climate change.
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.
Discussion of concerns with implementation of the domestic content requirements necessary to access elective pay provisions in the Inflation Reduction Act (Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702).
Discussed the need for timely guidance related to the implementation of Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702 (domestic content requirements for elective payment of energy tax credits).
Discussed S. 1793/H.R. 5803, the Grid Resiliency Tax Credit Act, to provide tax credits for the installation of regionally significant electric power transmission lines.
Discussed the need to restore advance refunding bonds and support for H.R. 1837, the Investing in Our Communities Act (all provisions), and S. 1453, supporting Lifting Our Communities through Advance Liquidity for Infrastructure Act or the LOCAL Infrastructure Act (all provisions).
Discussed support for legislation in the 117th Congress, H.R. 2634, the Local Infrastructure Financing Tools (LIFT) Act, section 4, to increase the small-issuer exception from $10 million to $30 million.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, Treasury - Dept of, U.S. SENATE, Energy - Dept of, White House Office, Office of Management & Budget (OMB)
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.
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 NAT
16. Specific lobbying issues
Discussed concerns with third-party efforts to remove the Lower Snake River Dams and the importance of hydropower (no bill).
Discussed concerns with practice by the Army Corps of Engineers to assign costs to Power Marketing Administration customers for which they receive no benefit (no bill).
Discussed the importance of the federal Power Marketing Administrations in providing reliable and affordable hydropower to public power utilities.
Discussed support for the continued existence and federal ownership of the Power Marketing Administrations and the sale of federally generated hydropower at cost-based rates.
Discussed support for S. 1324, the SWPA Fund Establishment Act (all provisions), to establish a fund that the Southwestern Power Administration may use for the operation and maintenance of power transmission facilities and other related expenses.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
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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John |
Godfrey |
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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 potential impact the Environmental Protection Agencys proposed greenhouse gas rules would have on public power utilities, as well as on affordability and reliability (EPA-HQ-OAR-2023-0072).
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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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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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 BUD
16. Specific lobbying issues
Discussed support of funding for the Low Income Home Energy Assistance Program in S. 2624, Departments of Labor, Health and Human Services, and Education, and Related Agencies Appropriations Act, 2024, and House Appropriations Committee draft version of same.
Discussed funding in draft energy and water appropriations bill for addressing the distribution transformer supply chain crisis.
Discussed including funding in S. 2443, Energy and Water Development and Related Agencies Appropriations Act, 2024, to address the distribution transformer supply chain crisis.
Discussed the need for relief from the Balanced Budget and Emergency Deficit Control Act of 1985, section 251A(6) (implementing direct spending reductions, i.e., sequestration) due its impact on public power utilities that issued direct payment bonds.
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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Amy |
Thomas |
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Corry |
Marshall |
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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
| 1 | 2 | 3 |
FOREIGN ENTITIES
27. Add the following foreign entities:
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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) |